Chap09-1 - Chapter 09 Nontaxable Exchanges Chapter 9...

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Chapter 09 - Nontaxable Exchanges Chapter 9 Nontaxable Exchanges Questions and Problems for Discussion 1. Although Company PJ must have expended $700,000 for the 1,000 acres, it did not take a cost basis in the land. Instead, PJ took a substituted basis of only $475,000 (basis of the property PJ surrendered in the nontaxable exchange). Therefore, PJ’s recognized gain on sale of the land will exceed the $600,000 appreciation by $225,000. 2. Because of the value-for-value presumption, the amounts realized by unrelated parties on the exchange of property are always equal. 3. The tax consequences to unrelated parties engaging in a nontaxable exchange are completely independent. For instance, one party could have a partially recognized gain while the other party could have an unrecognized loss. 4. The substituted basis of the qualifying property received in a nontaxable exchange can be more, less, or equal to the cost of the property, depending on the gain or loss deferred on the exchange. 5. a. If Firm A is transacting with the KLS Partnership itself, the contribution of property (the 2 percent interest in the MG Partnership) for a 10 percent equity interest in KLS is nontaxable to both Firm A and KLS Partnership. However, if the other party is a partner in KLS (not the partnership), the exchange is taxable to both parties. b. Mr. B’s exchange of land for RV stock is taxable to Mr. B but nontaxable to RV. c. Corporation C’s exchange of personalty for realty is taxable to both parties. d. Company D’s exchange of inventory for a new computer system is taxable to Company C. Not enough information is provided to determine if the exchange is taxable to the other party. 6. Because Firm Q is exchanging inventory for land, the exchange is taxable to Firm Q. Because Company M is exchanging business realty for investment realty, the exchange is a nontaxable, like-kind exchange to Company M. 7. Company W exchanged marketable securities for $250,000 of the $2 million FMV of Blackacre: this exchange does not qualify as a like-kind exchange. Consequently, Company W recognizes a $220,000 capital gain on the exchange. 8. If the value of the destroyed property exceeds the insurance reimbursement and the insurance reimbursement exceeds the property’s adjusted basis, the owner suffers an economic loss but realizes a gain. 9. A transfer of property to a corporation in exchange for the corporation’s stock is nontaxable only if the transferor (or group of transferors) owns 80 percent or more of the corporation immediately after the exchange. A transfer of property to a partnership in exchange for an equity interest is nontaxable regardless of the extent of the transferor’s ownership after the exchange. 10.
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This note was uploaded on 12/08/2010 for the course TAX 4011 taught by Professor Staff during the Spring '08 term at FAU.

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Chap09-1 - Chapter 09 Nontaxable Exchanges Chapter 9...

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