Gonzalez, a U.S. citizen, owns 1% of USAco, a domestic corporation. All other shareholders of USAco are unrelated foreign persons. In a Type B reorganization, FORco transfers shares of its voting stock to USAco shareholders in exchange for 100% of the stock in USAco. Gonzalez realizes a gain on the exchange. As a renowned and reputable international tax planning consultants, Gonzalez retains your services so that he can minimize any potential tax liabilities.
Relying on the concepts learned from the assigned materials for this module, in a brief advising Gonzalez, you are required to:
Discuss and make recommendations to him on how he can avoid the outbound-toll charge on the gain?
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Based on the facts provided in the scenario, this is a Type B reorganization which provides very limited flexibility, thus Gonzalez can avoid the outbound-toll charge on the gain resulting from the reorganization. As a shareholder of USAco Gonzalez strictly exchanges his 1% ownership of USAco’s stock for FORco’s voting stock meaning that the transaction does not trigger taxable gain. No cash can be used...
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