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Roland and bbrown - I stand corrected, nevertheless- would not the attain be the exact same and will never the new CPA need to have the for every asset/for every Be aware payable information and facts? Sorry to the confusion and happy you and Jon are presenting remarks on this thread. Remark
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Just require a reality Examine on the appropriate treatment method of the transaction. My consumer is vast majority proprietor in four entities (C-Corps) that agreed to contributed belongings and liabilities to a whole new C-Corp (NewCo). A few of the entities had liabilities in excessive of belongings. Nevertheless, in accordance with § 351 and § 357, we handled this as tax no cost exchange and did not report any achieve given that the 4 entities received no cash proceeds and retained equally Command and retained Main liability within the transferred liabilities. I just received a phone within the NewCo CPA indicating they were planning to report a phase up in basis to FMV around the NewCo tax return and was questioning why we did not report a obtain.
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