357 cash Fundamentals Explained
357 cash Fundamentals Explained
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Just need a reality check on the correct remedy of a transaction. My shopper is greater part owner in four entities (C-Corps) that agreed to contributed assets and liabilities to a whole new C-Corp (NewCo). A lot of the entities experienced liabilities in extra of assets. Though, in accordance with § 351 and § 357, we addressed this as tax free of charge exchange and didn't report any obtain given that the four entities gained no cash proceeds and retained both of those Regulate and retained Main liability within the transferred liabilities. I just obtained a simply call from the NewCo CPA expressing they ended up likely to report a phase up in foundation to FMV around the NewCo tax return and was questioning why we did not report a gain.
A lot many thanks and hope everyone seems to be aquiring a great weekend. "The toughest detail on the globe to be familiar with could be the cash flow tax" - Albert Einstein
At first posted by bbrownatl See Submit Alright, so it appears like a get needs to be regarded. Now, one further more problem. The Companies transferring all in their assets and liabilities had been within the cash basis of accounting.
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fourteen. Exactly what is the utmost total recoverable underneath the labor Corporation's fidelity bond for just a decline a result of any officer, staff or agent with the labor Corporation who taken care of union funds?
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In theory, I would just determine all liabilities in excess of all property and There may be the gain. Nonetheless, are accounts receivable and accounts payable handled in another way? "The hardest matter on earth to understand would be the money tax" - Albert Einstein
twelve. Throughout the reporting period of time did the labor organization have an audit or critique of its books and information by an out of doors accountant or by a mother or father overall body auditor/consultant?
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