Your Client Is a C Corporation That Wishes to Convert

question 39

Essay

Your client is a C corporation that wishes to convert to S status.Advise this corporation with respect to minimizing any § 1374 built-in gains tax.

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Definitions:

Treasury Stock

Shares of a company's own stock that it has repurchased from investors but not yet retired.

Consideration Transferred

The payment made by an acquirer to obtain control of an acquiree, which could include cash, assets, or other types of financial agreements.

Patent

A legal right granted by a government authority to an inventor or their assignee, giving them exclusive rights to produce, use, or sell an invention for a certain period of time.

Consideration Paid

The total amount of money or its equivalent paid or delivered by one party to another in exchange for goods, services, or assets.