Rich owns 60 of the 100 outstanding shares of Rainbow Corporation's stock and 80 of the 100 outstanding shares of Oz Corporation's stock. Rich's basis in his Rainbow shares is $12,000, and his basis in his Oz shares is $8,000. Rich sells 30 of his Rainbow shares to Oz Corporation for $50,000. At the end of the year of the sale, Rainbow and Oz Corporations have E&Ps of $25,000 and $40,000, respectively.a)What is the amount and character of Rich's gain or loss?b)What is Rich's basis in his remaining shares of the Rainbow and Oz stock?c)How does the sale affect the E&Ps of Rainbow and Oz Corporations?d)What basis does Oz Corporation take in the Rainbow shares it purchases?e)How would your answer to part (a) change if Rich owns only 50 shares of the 100 outstanding shares of Oz Stock?

What will be an ideal response?


a)The sale is recast as a redemption of Oz stock issued as a result of Rich's capital contribution of 
the Rainbow stock to Oz. The Sec. 302 stock ownership is tested by looking at Rich's ownership of the Rainbow stock.
Rich's ownership of Rainbow stock before the redemption: 60% of Rainbow stock.
Rich's ownership after the redemption: 30 shares directly and 80% × 30 shares indirectly = 
54 shares = 54% of Rainbow stock.
The redemption is treated as a $50,000 dividend to Rich since the combined E&P of Rainbow and Oz Corporations is $65,000 ($25,000 + $40,000).
b)Rich's basis in his remaining Rainbow stock is $6,000 (30/60 × $12,000). Rich's basis in his Oz 
stock is increased to $14,000 by his $6,000 basis in the redeemed Oz stock.
c)Oz's E&P is reduced by the first $40,000 of the distribution, and Rainbow's E&P is reduced by 
the remaining $10,000 ($50,000 - $40,000) of the distribution.
d)Oz's basis in its Rainbow shares is $6,000, the same as Rich's pre-sale basis.
e)If Rich owned only 50% of the Oz stock before the sale, Rich owns 60% of the Rainbow stock 
before and 45% after the sale [30 shares + (50% × 30 shares)], so the redemption is treated as a sale under Sec. 302(b)(2). Rich has a capital gain of $44,000 ($50,000 - $6,000 basis).

Business

You might also like to view...

When considering the agile project management process, at the end of each iteration

A. Stakeholders and customers review progress and reevaluate priorities. B. Product owner determines whether or not the project is complete. C. The Scrum master assigns daily tasks to team members. D. Team members are released to work on other projects. E. The Scrum master can terminate the project.

Business

In a straight commercial loan funds are typically used for what time period?

A. 180 days B. Up to one year C. Less than 30 days D. 30-90 days

Business

Typically, the articles of organization of a limited liability company (LLC) include information on how the LLC will be managed.?

Indicate whether the statement is true or false

Business

How is "disability" defined under the ADA?

Business