C vs S vs Partner Flashcards
Which type of entity is taxed at its formation?
None of them
What type of entity does the 80% ownership of control rule apply to?
C and S Corps
What is the shareholder’s tax basis during formation of a C and S Corps?
Adjusted Basis of Shareholder + Gain Recognized + Boot Paid - Boot Received - Liabilities Transferred to C Corp
Nonrecourse liabilities in this type of entity increase tax basis BUT NOT at-risk basis
S Corp
How is the gain or loss for shareholder determined if boot is received for C and S Corps?
Limited to lesser of: FMV Boot Received / Realized Gain
Which type of entity accepts services provided without being considered taxable?
None of them, with C and S corps it breaks that shareholder out of the 80% group
Which type of entity considers EXCESS liability as taxable boot?
Partnerships, excess liability is not assumed by other partners (Gain = Adj Basis of Contrib - Liab assumed)
G/L is generally recognized on which entities during formation?
None of them
What is the C-Corps/S-Corps basis in a shareholder during formation?
Adjusted (Shareholder) Basis + Gain Recognized by Shareholder
What is the partner’s basis in a partnership during formation?
Contribution (property at adj basis) - liabilities transferred + partner’s share of liabilities
What is the Partnership’s basis in a partner during formation?
Partner’s carryover basis + recognized gain by the incoming partner