Not known Details About 357 cash
Not known Details About 357 cash
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Just need a fact Examine on the appropriate remedy of the transaction. My consumer is majority proprietor in 4 entities (C-Corps) that agreed to contributed assets and liabilities to a different C-Corp (NewCo). A lot of the entities experienced liabilities in excess of property. Nevertheless, in accordance with § 351 and click here § 357, we handled this as tax no cost exchange and did not report any get because the four entities gained no cash proceeds and retained both Manage and retained primary liability about the transferred liabilities. I just bought a contact through the NewCo CPA indicating they were planning to report a action up in foundation to FMV over the NewCo tax return and was questioning why we didn't report a get.
I do think the answer here is by firm but make sure you suitable me if I'm Erroneous. For needs on the Sec. 357 achieve calc, I believe that is finished on someone company foundation, proper.
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