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Just require a truth Examine on the proper cure of the transaction. My client is bulk operator in four entities (C-Corps) that agreed to contributed belongings and liabilities to a whole new C-Corp (NewCo). Some of the entities had liabilities in excess of assets. While, in accordance with § 351 and § 357, we dealt with this as tax free exchange and didn't report any attain as the four entities gained no cash proceeds and retained both of those Handle and retained Major legal responsibility to the transferred liabilities. I just received a simply call in the NewCo CPA saying they have been going to report a action up in foundation to FMV around the NewCo tax return and was questioning why we did not report a get.
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fifteen. Throughout the reporting interval did the labor Firm acquire or eliminate any belongings in the way apart from purchase or sale?
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