What Does 357 cash Mean?
What Does 357 cash Mean?
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Just need a actuality Test on the proper treatment method of the transaction. My consumer is greater part proprietor in 4 entities (C-Corps) that agreed to contributed belongings and liabilities to a whole new C-Corp (NewCo). A few of the entities experienced liabilities in excessive of belongings. While, in accordance with § 351 and § 357, we treated this as tax free of charge exchange and didn't report any acquire because the 4 entities received no cash proceeds and retained both Command and retained primary legal responsibility over the transferred liabilities. I just bought a call in the NewCo CPA saying they have been gonna report a step up in basis to FMV to the NewCo tax return and was questioning why we did not report a obtain.
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13. In the course of the reporting interval did the labor organization learn any decline or lack of funds or other property? (Response "Yes" whether or not There have been repayment or Restoration.)
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Initially posted by BHoffman The achieve we ended up talking about might be only on that exact fastened asset that has a foundation decrease than the legal responsibility which was incurred to finance the acquisition of that exact mounted asset. This is certainly for each asset/for each Be aware payable so that you can't just lump every little thing collectively.
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Variable desire level – This is an desire fee that can adjust depending on the current index, like a major amount.
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