- 16 - The Partnership would recognize gain on the sale of the private placement note calculated as follows: Cash 160.0 Basis 33.3 (1/6 of 200) _____ Gain 126.7 BC's Gain 12.67 FP's Gain 114.03 Total Gain 126.70 BC's share of the gain equals its 10% ownership in the Partnership for a taxable gain to BC of $12.67 million in 1990. Step 4: In April 1990 or later, (i.e. until there has been some movement in the value of the contingent note) BC buys 50% of FP's interest in the Partnership for $90 million, assuming that the fmv of the contingent note is still $40 million. With this purchase, BC's basis in its Partnership interest is $122.67 million calculated as follows: BC's initial investment $20.0 million Gain 12.67 Purchase of 50% of FP's interest 90.00 122.67 Step 5: The Partnership distributes the contingent note to BC assuming a fmv of $40 million. In addition, the Partnership would distribute approximately $32.72 million in cash to FP which is the equivalent cash distribution to FP given its percentage ownership. Step 6: BC sells the contingent note for cash. This sale of the contingent note by BC generates the capital loss.Page: Previous 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Next
Last modified: May 25, 2011