Nontaxable quadrant

Question 1

Q1- acquire assets, operate as division

Answer 1

A or C reorg-368
A:no G/L recognized-1032; basis of assets (C/O)-362
T: No G/L recognized on exchange-361; no G/L recognized on liquidation-361; tax attributes c/o to A-381
SHt: No G/L recognized- 354; Basis of stock (substituted)-358

Question 2

Q2- acquire assets, operate as a subsidiary

Answer 2

A or C reorg-368
initially the same as Q1
A: no G/L on formation of New Corp-351; basis of NewCorp(substituted)-358
NC: No G/L recognized -1032; basis in assets(C/O)-362; attributes stay with A-381

Question 3

Q3-acquire stock, operate as division

Answer 3

A or C reorg-368

Same as Q1 (steps collapsed into 1)

Question 4

Q4-acquire stock, operate as subsidiary

Answer 4

B reorg-368
SHt: No G/L recognized-354; basis in A stock(substituted)-358
A: No G/L recognized-1032; basis of T stock (C/O)-362
T: no change