|Discuss the difference between gain realization and gain recognition in a property transaction.|
|2.||(LO1)What information must a taxpayer gather to determine theamount realizedin a property transaction?|
|3.||(LO1)Distinguish between exclusion and deferral as it relates to a property transaction.|
|4.||(LO1)Discuss how a taxpayer’s tax basis in property received in a property transaction will be affected based on whether a property transaction results in gain exclusions or gain deferral.|
|5.||(LO1)What information must a taxpayer gather to determine thetax-adjusted basisof property exchanged in a property transaction?|
|6.||(LO2)Why does Congress allow tax deferral on the formation of a corporation?|
|7.||(LO2)List the key statutory requirements that must be met before a corporate formation is tax-deferred under §351.|
|8.||(LO2)What is the definition ofcontrolfor purposes of §351? Why does Congress require the shareholders to control a corporation to receive tax deferral?|
|9.||(LO2)What is asubstituted basisas it relates to stock received in exchange for property in a §351 transaction? What is the purpose of attaching a substituted basis to stock received in a §351 transaction?|
|10.||(LO2)True or False. The receipt of boot by a shareholder in a §351 transaction causes the transaction to be fully taxable. Explain.|
|11.||(LO2)True or False. A corporation’s assumption of shareholder liabilities will always constitute boot in a §351 transaction. Explain.|
|12.||(LO2)How does the tax treatment differ in cases where liabilities are assumed with a tax avoidance purpose versus where liabilities assumed exceed basis? When would this distinction cause a difference in the tax treatment of the transactions?|
|13.||(LO2)What is acarryover basisas it relates to property received by a corporation in a §351 transaction? What is the purpose of attaching a carryover basis to property received in a §351 transaction?|
|14.||(LO2)Under what circumstances does property received by a corporation in a §351 transaction not receive a carryover basis? What is the reason for this rule?|
|15.||(LO2)How does a corporation depreciate an asset received in a §351 transaction in which no gain or loss is recognized by the transferor of the property?|
|16.||(LO2)True or False. A shareholder receives the same tax consequences whether property is contributed to a corporation in a §351 transaction or as a capital contribution. Explain.|
|17.||(LO2)Why might a corporation prefer to characterize an instrument as debt rather than equity for tax purposes? Are the holders of the instrument indifferent as to its characterization for tax purposes?|
|18.||(LO2)Under what conditions is it advantageous for a shareholder to hold §1244 stock? Why did Congress bestow these tax benefits on holders of such stock?|
|19.||(LO3)Why does the acquiring corporation usually prefer to buy the target corporation’s assets directly in an acquisition?|
|20.||(LO3)Why do the shareholders of the target corporation usually prefer to sell the stock of the target corporation to the acquiring corporation?|
|21.||(LO3)What is the Congressional purpose for allowing tax deferral on transactions that meet the definition of a corporate reorganization?|
|22.||(LO3)Why do publicly traded corporations use a triangular form of Type A reorganization in acquiring other corporations?|
|23.||(LO3)What are the key differences in the tax law requirements that apply to forward versus reverse triangular mergers?|
|24.||(LO3)What are the key differences in the tax law requirements that apply to a Type A stock-for-assets acquisition versus a Type B stock-for-stock acquisition?|
|25.||(LO4)How does the form of a regular §338 election compare and contrast to a §338(h)(10) election?|
|26.||(LO4)What tax benefits does the buyer hope to obtain by making a §338 or §338(h)(10) election?|
|27.||(LO4)What is the difference between theinside tax basisand theoutside tax basisthat results from an acquisition? Why is the distinction important?|
|28.||(LO4)What is the presumption behind the continuity of ownership interest (COI) requirement in a tax-deferred acquisition? How do the target shareholders determine if COI is met in a Type A reorganization?|
|29.||(LO4)W Corporation will acquire all of the assets and liabilities of Z Corporation in a Type A merger, after which W Corporation will sell off all of its assets and liabilities and focus solely on Z Corporation’s business. True or False: The transaction will be taxable because W Corporation fails thecontinuity of business enterprise test.Explain.|
|30.||(LO4)Compare how a shareholder computes her tax basis in stock received from the acquiring corporation in a straight Type A merger versus a Type B merger.|
|31.||(LO5)True or False. All shareholders receive the same tax treatment in a complete liquidation of a corporation. Explain.|
|32.||(LO5)True or False. A corporation recognizes all gains and losses on liquidating distributions of property to noncorporate shareholders. Explain.|
|33.||(LO5)Under what circumstances does a corporate shareholder receive tax deferral in a complete liquidation?|
|34.||(LO5)Under what circumstances will a liquidating corporation be allowed to recognize loss in a non-pro rata distribution?|
|35.||(LO5)Compare and contrast the built-in loss duplication rule as it relates to §351 with the built-in loss disallowance rule as it applies to a complete liquidation.|
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