357 cash No Further a Mystery
357 cash No Further a Mystery
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Just have to have a truth check on the right cure of the transaction. My customer is majority owner in four entities (C-Corps) that agreed to contributed property and liabilities to a new C-Corp (NewCo). A lot of the entities had liabilities in excess of assets. However, in accordance with § 351 and § 357, we taken care of this as tax free Trade and did not report any acquire as being the four entities received no cash proceeds and retained both of those Manage and retained Principal liability around the transferred liabilities. I just got a call within the NewCo CPA expressing they were being gonna report a step up in foundation to FMV on the NewCo tax return and was questioning why we did not report a gain.
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" I think this concept would use to each from the four transferor corps, not into the blended amounts for all four transferor corps taken in general.
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The county company presented to assist the applicant in getting the necessary verifications when asked for with the applicant, or when the county company was capable to obtain the verifications a lot quicker, assuming the applicant didn't refuse to cooperate.
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This is for each asset/per Observe payable so that you can't just lump everything jointly. Maybe it is advisable to focus on this with The existing CPA so you happen to be on the identical web site? The numbers do really have to coordinate and I would talk to with him or her.
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