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(a) A provision to carry the employer harmless need to The us government realize that the employer or the employee is indebted to the United States on account of:

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Just need a fact Examine on the appropriate treatment method of the transaction. My consumer is bulk operator in 4 entities (C-Corps) that agreed to contributed assets and liabilities to a different C-Corp (NewCo). A number of the entities experienced liabilities in excessive of assets. While, in accordance with § 351 and § 357, we handled this as tax absolutely free Trade and didn't report any achieve since the 4 entities received no cash proceeds and retained equally Command and retained Main liability to the transferred liabilities. I just got a get in touch with in the NewCo CPA expressing they were being planning to report a step up in basis to FMV around the NewCo tax return and was questioning why we did not report a obtain.

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