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:

Opposite Number

The number with the same magnitude but opposite sign to a given number, effectively located on the opposite side of zero on the number line.

Overbar Symbol

A notation used in mathematics to indicate that the value or sequence beneath the bar is repeated infinitely.

Decimal Representation

The expression of numbers in a base-10 system, involving a sequence of digits to the right and left of a decimal point.

Distance

The amount of space between two points, usually measured along the shortest path connecting them.