WFT_Ch 07_Vol 2_SM

WFT_Ch 07_Vol 2_SM - Path:

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Path: K:/TL-WFT-05-0802/Application/TL-WFT-05-0802-007_V2-SM.3d Date: 12th April 2006 Time: 17:04 User ID: 40223 CHAPTER 7 CORPORATIONS: REORGANIZATIONS SOLUTIONS TO PROBLEM MATERIALS Question/ Problem Topic Status: Present Edition Q/P in Prior Edition 1 Industry with bankruptcies New 2 Treatment of taxable reorganization gains Unchanged 2 3 General requirements for reorganizations Unchanged 3 4 Like-kind exchange versus corporate reorganization Unchanged 4 5 Dividend and stock redemption treatment New 6 Type ‘‘B’’ reorganizations Unchanged 6 7 ‘‘B’’ reorganization Unchanged 7 8 ‘‘C’’ reorganization Unchanged 8 9 Comparison of ‘‘Type A’’ and ‘‘Type C’’ reorganizations New 10 Comparison of ‘‘Type B’’ and ‘‘Type C’’ reorganizations New 11 Divisive ‘‘D’’ reorganizations Unchanged 9 12 ‘‘E’’ reorganization Unchanged 10 13 ‘‘F’’ reorganization Unchanged 11 14 ‘‘G’’ reorganization New 15 Section 382 and judicial doctrines New 16 ‘‘Type C’’ and step transaction doctrine New 17 Application of § 381 limitation New 18 Ownership change for § 382 Unchanged 16 19 Postponement of losses by § 382 Unchanged 17 20 Continuity of interest Unchanged 18 21 Year of reorganization § 382 limitation New 22 Excess credit § 382 limitation computation New 23 Unchanged 19 *24 Carryover of loss attributes Unchanged 20 25 Avoiding ownership change New *26 Classify as to type of reorganization Unchanged 21 27 Gain taxable as dividend and capital Unchanged 22 28 Reorganization gain, loss, and basis determination New 7-1
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Path: K:/TL-WFT-05-0802/Application/TL-WFT-05-0802-007_V2-SM.3d Date: 12th April 2006 Time: 17:04 User ID: 40223 Question/ Problem Topic Status: Present Edition Q/P in Prior Edition 29 Dividend computation New 30 Securities received in reorganization New 31 Effect on basis when gain recognized Unchanged 23 *32 Gain recognition and basis computation Unchanged 24 33 Gain to target corporation in a reorganization Unchanged 25 34 Gain to acquiring corporation in a reorganization Unchanged 26 35 Comparison of ‘‘A’’, ‘‘C,’’ and acquisitive ‘‘D’’ reorganizations Unchanged 27 36 ‘‘B’’ reorganization Unchanged 28 37 ‘‘C’’ reorganization Unchanged 29 38 ‘‘D’’ reorganization Unchanged 30 39 ‘‘D’’ reorganization Unchanged 31 *40 ‘‘E’’ reorganization Unchanged 32 41 ‘‘E’’ reorganization Unchanged 33 42 ‘‘G’’ reorganization Unchanged 34 43 Sound business purpose and continuity of business enterprise Unchanged 35 44 Continuity of interest and step transaction Unchanged 36 45 NOL carryover when no § 382 limitation New 46 NOL carryover change year and § 382 limitation New 47 Capital loss carryover and continuity of business New *48 Net operating loss carryover Unchanged 37 49 Carryover of net operating losses Unchanged 38 50
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WFT_Ch 07_Vol 2_SM - Path:

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