TAX 9866 Lecture Notes - Lecture 7: Preferred Stock, United States Treasury Security, Foreign Corporation

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20 Dec 2019
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Corporate taxation examples for final: i have two minor children and because they are minor mom & dad are in charge of money/control shares of stock. I own 50 shares, give each daughter 25 shares. Have company redeem my 50% of my shares. Go thru 302 mechanical test; and say yes, i get sale exchange treatment. What type of attribution is this: suppose a shareholder owns 89 shares prior to sale and then after the sale she owns 51 shares. She goes and files stmt to waive 318 attribution and promises never to acquire a prohibited interest in corp in next 10 yrs. Two years later grand father dies and leaves all shs to mother. Within 10 yr period she acquired prohibited interest directly. Does she fail: what are the prohibited interests, grandfather owns 25 shares, mother owns 50 shares and grandson owns 10 shares of xyz corp.

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