Two individuals plan to form a consulting corporation. Person A contributes appreciated property for stock and would own 79% immediately after. Person B receives stock solely for services and would own 21% immediately after. No other property contributors participate. What is the §351 outcome for A’s transfer?

A manufacturing company has a temporary difference because tax depreciation exceeds book depreciation by $600, expected to reverse evenly over the next three years ($200 per year). At a 21% statutory rate, what initial deferred tax liability (DTL) should be recorded at year-end?

In a qualifying §351 exchange, a contributor transfers two operating assets to NewCo: inventory (AB $50; FMV $90) and §1245 equipment (AB $70; FMV $130). The contributor also receives $40 of cash (boot). Using relative FMVs, how should the $40 boot be allocated for character purposes?

At year-end, a company carries a DTL of $126 related to accelerated tax depreciation that is scheduled to reverse entirely next year. During the current year, tax legislation is enacted that increases the statutory tax rate to 25% effective next year. What remeasurement effect, if any, should be recognized in the current period’s income tax expense?

Under the post-2017 NOL rules, a C corporation has taxable income of $800 before NOL and possesses $900 of indefinite-lived NOL carryforwards. How much NOL may be utilized this year?

Using the facts above (AB $180; liability relief $40; boot $15) and assuming recognized gain is $15, what is the corporation’s basis in the transferred property under §362?

Timing of control: A forms NewCo this quarter and initially owns 100%. Three months later, B contributes appreciated equipment for a 30% interest; A’s ownership falls to 70%. No boot is paid. From B’s standpoint, which statement best describes the §351 outcome?

When a corporation’s cash charitable contributions exceed the current-year limit, how is the excess generally treated (ignore temporary statute changes)?

At formation, the parties contribute assets with mixed gains and losses: A transfers loss property (AB $200; FMV $150), and B transfers gain property (AB $100; FMV $190). Assuming §351 applies and the parties do not elect to reduce stock basis, how does §362(e)(2) affect the corporation’s basis in the loss property?

Computational — Corporate Operations (NUMERIC only; CC → DRD) Facts: TI before CC/DRD/NOL = 1,480; CC paid = 210; dividends received = 520 from a 22%-owned domestic corporation; no NOLs. Apply 10% CC limit and §243 rates with ordering CC → DRD. (a1) DRD percentage (enter 50, 65, or 100):  [a1] (a2) DRD amount: [a2] (a3) Does the DRD taxable-income limitation bind? Enter 1 if YES, 0 if NO: [a3] (b1) Allowable current-year CC deduction: [b1] (b2) CC carryforward (if any): [b2] (c) Final taxable income: [c]