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JBC Corporation is owned 20 percent by John, 30 percent by Brian, 30 percent by Charlie, and 20 percent by Z Corporation. Z Corporation is owned 80 percent by John and 20 percent by an unrelated party. Brian and Charlie are brothers. Answer each of the following questions about JBC under the constructive ownership rules of Section 267:<?xml:namespace prefix = o ns = "urn:schemas-microsoft-com:office:office" />a. What is John's percentage ownership?b. What is Brian's percentage ownership?c. What is Charlie's percentage ownership? _________%d. If Brian sells property to JBC for a $6,000 loss, what amount of that loss can be recognized for tax purposes (before any annual limitations)?

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jepessoa

Answer:

a. What is John's percentage ownership?

  • 36%

b. What is Brian's percentage ownership?

  • 60%

c. What is Charlie's percentage ownership?

  • 60%

d. If Brian sells property to JBC for a $6,000 loss, what amount of that loss can be recognized for tax purposes (before any annual limitations)?

  • $0

Explanation:

JBC Corporation:

  • 20 percent by John
  • 30 percent by Brian
  • 30 percent by Charlie
  • 20 percent by Z Corporation

Z Corporation:

  • 80 percent by John
  • 20 percent by an unrelated party

Under constructive ownership rules of Section 267, family members included in constructive ownership are siblings, parents, grandparents, and children.

John owns = 20% + (20% x 80% of Z Corporation) = 36%

Brian = 30% + 30% (Charlie) = 60%

Charlie = 30% + 30% (Brian) = 60%

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