Parent Corporation Owns 100% of the Stock of Subsidiary Corporation

question 30

Essay

Parent Corporation owns 100% of the stock of Subsidiary Corporation. The adjusted basis of its stock investment is $100,000. A plan of liquidation is adopted. Subsidiary distributes to Parent assets with a $325,000 FMV and a $275,000 adjusted basis. Subsidiary also distributes liabilities in the amount of $40,000. Subsidiary has a $150,000 E&P balance.
a)What is the amount and character of Subsidiary Corporation's recognized gain or loss on the distribution?
b)What is the amount and character of Parent Corporation's recognized gain or loss on the redemption of the Subsidiary stock?
c)What basis does Parent take in the assets?
d)What happens to parent Corporation's basis in the Subsidiary stock and to Subsidiary's tax attributes?

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Definitions:

Exemption Clause

A part of a contract that seeks to limit a party's liability for breaches of the contract or negligence, often subject to legal restrictions.

Bailment Contract

An agreement where physical possession of personal property is transferred from one party to another, with the understanding that the property will be returned.

Contract Frustration

A legal principle that releases both parties from their contractual obligations when an unforeseen event renders the contract physically or commercially impossible to perform.

Commission Payment

A method of remuneration for services or facilitating transactions, typically calculated as a percentage of the transaction value.