taxable quadrant

Question 1

Q1- sale and purchase of assets, operate as a business

Answer 1

T: G/L recognized on sale- 1001; tax on gain-11; no G/L on liquidation-336; e&p, etc. disappear- 381 N/A
SHt: G/L recognized on liquidation-331; tax on gain-1
P: cost basis-1012

Question 2

Q2-sale and purchase of assets, operate as subsidiary

Answer 2

T, SHt, P- same as Q1
P: No G/L recognized on formation of sub-351; basis in Psub stock(substituted)-358
Psub: No G/L on formation-1032; basis of assets C/O-362

Question 3

Q3-sale and purchase of stock (w/o 338), operate as buisness

Answer 3

on purchase of T stock- SHt, P, T same as Q4
on liquidation:
P: No G/L recognized-332; basis of assets (C/O)-334; basis of T stock disappears
T: No G/L recognized -337; attributes c/o to P-381

Question 4

Q4-sale and purchase of stock, operate as subsidiary

Answer 4

SHt:G/L recognized on sale of Tstock- 1001; tax on gain 1
P: basis in T stock (cost) 1012
T: no change, same as Q1