Basic question about asset contribution to Corp vs Partnership

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  • #195015
    damingli85
    Participant

    For the sake of argument

    Asset

    Adj basis/NBV= 10,000

    FMV = 50,000

    If I form a corporation and give the corporation the asset, the corporation’s basis in the asset would be the 50,000 FMV.

    But if I form a partnership and give the partnership the asset, the partnership’s basis in the asset would be 10,000 adj basis/NBV.

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  • #675268
    sdguy
    Participant

    I think it's carryover basis in both scenarios. As long as in the corp scenario, it's only property and cash bring contributed (no services)

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    #675269
    Last Chance CPA
    Participant

    The control test (80% stock and ownership) must be applied for Corps, right sdguy? Since SH is forming the corp, he must own the corporation after the distribution. In that case, the corporation will take it at basis (plus any gain recognized by the SH).

    Partnerships are pretty much always at carryover basis since they are just flow-through entities…

    Holy crap – I think this stuff is finally kicking in!

    AUD - 75
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    I want those initials next to my name!!!!

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    Now I need some experience!!! And some networking...

    #675270
    sdguy
    Participant

    Yes 80% exactly, but in his example he only mentioned property.

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