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If the requirements of ----------- are met, no gain or loss is recognized when property is transferred to a corporation.
If the requirements of Sec. 351(a) are met, no gain or loss is recognized when property is transferred to a corporation.
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If the requirements of Sec. 351(a) are met, no------------------------------- when property is transferred to a corporation.
If the requirements of Sec. 351(a) are met, no gain or loss is recognized when property is transferred to a corporation.
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------------------- defines control as the ownership of at least 80% of both the voting and nonvoting stock.
Section 368(c) defines control as the ownership of at least 80% of both the voting and nonvoting stock.
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Neither the parent corporation nor a controlled subsidiary recognizes ----------------- on a liquidating distribution to the parent.
Neither the parent corporation nor a controlled subsidiary recognizes gain or loss on a liquidating distribution to the parent.
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When an asset is sold at a higher price than its original purchase price, a --------------------- is achieved, which increases the current assets.
When an asset is sold at a higher price than its original purchase price, a realized gain is achieved, which increases the current assets.
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------------------------- is a gain earned by selling an asset at a price higher than the original purchase price.
Realized gain is a gain earned by selling an asset at a price higher than the original purchase price.
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Recognized gain is the lesser of -----------------------------------.
Recognized gain is the lesser of boot received and realized gain.
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------------------ can apply to contributions of property to a corporation even if the corporation issues no stock in the exchange, such as capital contributed by a sole shareholder.
Section 351 can apply to contributions of property to a corporation even if the corporation issues no stock in the exchange, such as capital contributed by a sole shareholder.
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A ---------------------------------- recognizes no gain or loss upon the receipt of a liquidating distribution from a controlled corporation.
A parent corporation recognizes no gain or loss upon the receipt of a liquidating distribution from a controlled corporation.
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Section 302(b)(4) allows shareholders who receive redemptions in partial liquidation to treat the distribution as------------------------------------------------------
Section 302(b)(4) allows shareholders who receive redemptions in partial liquidation to treat the distribution as payment for their stock.
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Section 351 requires that ---------------------------------- if property is transferred to a corporation by one or more persons solely in exchange for stock in the corporation and immediately after the exchange, such person or persons control the corporation.
Section 351 requires that no gain or loss be recognized if property is transferred to a corporation by one or more persons solely in exchange for stock in the corporation and immediately after the exchange, such person or persons control the corporation.
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Gain realized on distributed property must be recognized by the corporation as if the property was sold ---------------------------.
Gain realized on distributed property must be recognized by the corporation as if the property was sold at its fair market value.
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---------- is not established if the activity is limited to solicitation of orders for tangible personal property; the orders are sent out of state for approval or rejection and, if approved, the orders are filled by shipment or delivery from a point outside the state.
Nexus is not established if the activity is limited to solicitation of orders for tangible personal property; the orders are sent out of state for approval or rejection and, if approved, the orders are filled by shipment or delivery from a point outside the state.
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Section 351 requires that no gain or loss be recognized if property (e.g., cash, tangible property, intangible property) is transferred to a corporation by one or more persons solely in exchange for stock in the corporation and, immediately after the exchange, such person or persons control the corporation. This nonrecognition treatment is -------------------------------.
Section 351 requires that no gain or loss be recognized if property (e.g., cash, tangible property, intangible property) is transferred to a corporation by one or more persons solely in exchange for stock in the corporation and, immediately after the exchange, such person or persons control the corporation. This nonrecognition treatment is mandatory, not elective.
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Control is ownership of -------- or more of the voting power of stock and -------- or more of the shares of each class of nonvoting stock of the corporation.
Control is ownership of 80% or more of the voting power of stock and 80% or more of the shares of each class of nonvoting stock of the corporation.
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No loss realized on an ordinary distribution of property (AB > FMV) may be recognized. The shareholder takes a -------------- in the property.
No loss realized on an ordinary distribution of property (AB > FMV) may be recognized. The shareholder takes a FMV basis in the property.
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------------------------------------- are undeclared distributions to shareholders
Constructive dividends are undeclared distributions to shareholders
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Treat a distribution of ------------------------- as a distribution of the stock.
Treat a distribution of stock rights as a distribution of the stock.
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Any excess of the amount of a distribution over E&P and basis is treated as -----------------------------------------.
Any excess of the amount of a distribution over E&P and basis is treated as gain on the sale of the stock.
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An ---------------------------------- is a dividend on stock held 2 years or less that exceeds 10% (5% for preferred stock) of either the basis or the FMV of the stock.
An extraordinary dividend is a dividend on stock held 2 years or less that exceeds 10% (5% for preferred stock) of either the basis or the FMV of the stock.
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Basis in a stock acquired by exercising a stock right is ---------------------------------------------------------------
Basis in a stock acquired by exercising a stock right is any basis allocated to the right, plus the exercise price.
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A corporation recognizes gain realized on a distribution
----------------------------------------------------
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A corporation recognizes gain realized on a distribution
As if the property distributed were sold at FMV to the distributee immediately prior to the distribution
Even if stock is redeemed by the distribution
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No recognition of loss realized is allowed by the corporation, unless the redemption is
----------------------------------------- or
---------------------------------------------
No recognition of loss realized is allowed by the corporation, unless the redemption is
In complete liquidation of the corporation or
Of stock held by an estate (to pay death taxes).
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A corporation recognizes ordinary income on the distribution of depreciated property to the extent of ------------------------------------------------------------------------------------
A corporation recognizes ordinary income on the distribution of depreciated property to the extent of depreciation or amount realized, whichever is less.
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-------------------------------------- to a dividend means that there is a meaningful reduction in the shareholder’s proportionate interest in the corporation. Reduction in voting power is generally required.
Not essentially equivalent to a dividend means that there is a meaningful reduction in the shareholder’s proportionate interest in the corporation. Reduction in voting power is generally required.
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A corporation must file an information return (Form 966, Corporate Dissolution or Liquidation) reporting adoption of a plan or resolution for its dissolution, or partial or complete liquidation, within -------------------------------.
A corporation must file an information return (Form 966, Corporate Dissolution or Liquidation) reporting adoption of a plan or resolution for its dissolution, or partial or complete liquidation, within 30 days of adoption.
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The corporation making the distribution recognizes --------------------------------
The corporation making the distribution recognizes gain but not loss.
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Neither the parent corporation nor a controlled subsidiary recognizes ---------------- on a liquidating distribution to the parent.
Neither the parent corporation nor a controlled subsidiary recognizes gain or loss on a liquidating distribution to the parent.
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In a ----------------------------, a shareholder recognizes no gain or loss on an exchange of stock or securities solely for stock or securities in the same or another corporation that is a party to the -------------------------------
In a reorganization, a shareholder recognizes no gain or loss on an exchange of stock or securities solely for stock or securities in the same or another corporation that is a party to the reorganization
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---------------------------------------- Under state law, two corporations merge into one. Stock in the non-surviving corporation is canceled. In exchange, its shareholders receive stock in the surviving corporation.
Statutory merger or consolidation. Under state law, two corporations merge into one. Stock in the non-surviving corporation is canceled. In exchange, its shareholders receive stock in the surviving corporation.
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---------------------------------------- Shareholders acquire stock of a corporation solely for part or all of the voting stock of the acquiring corporation or its parent.
Type B: Stock-for-stock. Shareholders acquire stock of a corporation solely for part or all of the voting stock of the acquiring corporation or its parent.
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------------------------------------- One corporation acquires substantially all the assets of another in exchange for its voting stock (or its parent’s). The transferor (sale of assets) corporation must liquidate.
Type C: Stock-for-assets. One corporation acquires substantially all the assets of another in exchange for its voting stock (or its parent’s). The transferor (sale of assets) corporation must liquidate.
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---------------------------------- The capital structure of the corporation is modified by exchanges of stock and securities between the corporation and its shareholders.
Type E: Recapitalization. The capital structure of the corporation is modified by exchanges of stock and securities between the corporation and its shareholders.
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-------------------------------------- Stock and securities are exchanged upon a mere change in the name, form, or place of incorporation.
Type F: Reincorporation. Stock and securities are exchanged upon a mere change in the name, form, or place of incorporation.
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--------------------------------------------- Stock, securities, and property are exchanged pursuant to a court-supervised bankruptcy proceeding.
Type G: Bankruptcy reorganization. Stock, securities, and property are exchanged pursuant to a court-supervised bankruptcy proceeding.
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Before a state can tax a nonresident, a minimum presence in the taxing state by the nonresident must be established. Substantial presence to tax the nonresident is known as ---------------
Before a state can tax a nonresident, a minimum presence in the taxing state by the nonresident must be established. Substantial presence to tax the nonresident is known as nexus.
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