Not known Factual Statements About 357 cash
Not known Factual Statements About 357 cash
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Just have to have a reality check on the right therapy of the transaction. My consumer is greater part operator in four entities (C-Corps) that agreed to contributed property and liabilities to a fresh C-Corp (NewCo). Several of the entities experienced liabilities in excess of assets. Although, in accordance with § 351 and § 357, we treated this as tax free exchange and didn't report any gain as being the four entities acquired no cash proceeds and retained each Management and retained Major liability around the transferred liabilities. I just bought a phone within the NewCo CPA expressing they were going to report a phase up in basis to FMV within the NewCo tax return and was questioning why we did not report a gain.
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" I feel this concept would implement to every in the four transferor corps, not towards the put together amounts for all 4 transferor corps taken in general.
Repossess – The voluntary or forced surrender of things in the case of the consumer’s failure to pay for again a personal loan.
There might be other concerns relating to A/R and also a/P, but Those people would depend on how the offer was structured.
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