Jerry operated his business as a single member LLC for several years when Mega C

Question

Jerry operated his business as a single member LLC for several years when Mega Corporation asked him to "join-up" in its operations. Under the plan, Jerry would transfer the assets and liabilities of the LLC to a newly-formed Mega Corporation subsidiary. Jerry would transfer assets with a basis of $250,000 (FMV = $480,000) and $80,000 in liabilities and would receive 40% of the stock of the subsidiary. Mega would transfer assets with a basis and fair market value of $600,000, and would receive 60% of the subsidiary stock.

a. Compute Jerry's recongized gain on the transfer

b. Compute Jerry's basis in the stock

c. What is the corporation's basis in the assets transferred by Jerry

d. Compute the corporation's basis in the assets Jerry transferred assuming their basis to Jerry was $600,000 and their fair market value was $480,000. Explain the basis for your answer.

Explanation / Answer

a) Calculation of Jerry's recognised gain on Transfer:

Recognised Gain to Jerry would be 0.

Reason: The transfer fulfill the rquirement of Sec 351so No gain or Loss would be recognised. And the transaction would be treated as 'Nothing Happened'.

b) Jerry's basis of the Stock: Calculation of Jerry's basis of the stock:

Adjusted Basis of the Property = 250,000

Add: Gain recognised = 0

Less: Value of Liability = 80,000

So,Jerry's basis of Stock would be $170,000

c) Corporation's basis in the Asset transferred by Jerry:

Adjusted basis of property for Jerry would be the Corporation's Basis in the Asset.

So, Corporation's basis in the Asset is $250,000

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