• Tell scenario where the transfer of property to a controlled corporation under Section 351 of the Internal Revenue Code (IRC) results in the taxation to the transferor. Speculate as to the reasons that gain treatment in the current year may be preferred to the deferral of gain. Provide a tax-planning strategy to prevent taxation of similar transfers.
  • Section 267 of the IRC disallows a deduction on losses realized on the sale of property and a deduction for accrued expenses between a corporation and a controlling shareholder. Generally Accepted Accounting Principles (GAAP) does not include this disallowance provision. Explain argument for allowing a loss on a sales transaction between a controlled corporation and shareholder when the transaction includes an independent appraisal and the loss is similar to losses incurred in arm’s length transactions. Provide an example of allowing such loss to support your argument.

Please explain the above and give examples.