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:

Equity Securities

Equity securities represent ownership interest held by shareholders in an entity, such as stocks, signaling a claim on its proportionate share in the corporation's assets and profits.

Non-Current Section

A section of the balance sheet that lists long-term liabilities and assets that are not expected to be liquidated or paid off within one year.

Long-Term Investments

Investments in securities, bonds, real estate, or other assets intended to be held for a period exceeding one year for capital gains, dividends, or interest earnings.

Balance Sheet

A summary report of a corporation’s assets, liabilities, and the owners’ equity as recorded at a specific moment in time.