Publication 542 |
2000 Tax Year |
Capital Contributions
This section explains the tax treatment of contributions from
shareholders and nonshareholders.
Paid-in capital.
Contributions to the capital of a corporation, whether or not by
shareholders, are paid-in capital. These contributions are not taxable
to the corporation.
Basis.
The basis of property contributed to capital by a shareholder is
the same as the basis the shareholder had in the property, increased
by any gain recognized on the exchange.
The basis of property contributed to capital by a person other than
a shareholder is zero.
If a corporation receives a cash contribution from a person other
than a shareholder, the corporation must reduce the basis of any
property acquired with the contribution during the 12-month period
beginning on the day it received the contribution by the amount of the
contribution. If the amount contributed is more than the cost of the
property acquired, then reduce, but not below zero, the basis of the
other properties held by the corporation on the last day of the
12-month period in the following order.
- Depreciable property.
- Amortizable property.
- Property subject to cost depletion but not to percentage
depletion.
- All other remaining properties.
Reduce the basis of property in each category to zero before going
to the next category.
There may be more than one piece of property in each category. Base
the reduction of the basis of each property on the ratio of the basis
of each piece of property to the total bases of all property in that
category. If the corporation wishes to make this adjustment in some
other way, it must get IRS approval. The corporation files a request
for approval with its income tax return for the tax year in which it
receives the contribution.
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