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Sox years ago, Donna purchased land as an investment. The land cost $150,000 and is now worth $480,000. Donna plans to transfer the land to Development Corporaton, which wh subdivide if and sel individual tracts. Development's income on the land sales will be ordinary in character. Read the requirements. Requirement a. What are the tax consequences of the asset transfer and land sales it Donna contributes the land to Development in exchange for all its stock? Donna recognizes on the transfer of land to Devolopment Corporation. Developmenfs basis in the land will be All gain on the subsequent sales will be to Development. Requirement b. In what altemative wibys can the transaction be structured to achieve more favorable tax results? Assume Donna's marginal tax rate for capifal gains is 23 ang fiof +3.8% on net investment inoome), and Developments tax rate is 21%. A. Donna could elect out of the Sec. 351 provisions. By including an election with her timely fled income tax raturn in the year of the transfer, Donna can avoid the Sec. 351 provisions. B. There are no altematives that will allow Donna to avoid Sec. 351. C. Donna could find another investor who is willing to contritule preperty valued at 3150.000 in exchange for soks of the stock of the corporation. D. Donna could transfer the land to Develogment in exchange for stock and debt instruments eeval to her reolited gain. In this case. Dorrar would racognize a long tarre cacilat gain and Developments basis in the land would be the F MV of the land. The pre-contribucion captal gain (nat of any capital losses that Donna has recognized) is tareed at the apolicable caphal gains tax rate (in this case, 23.8%, including the 3.8% net investment fax). The step-up in bavis permits Develcement to uee ine adelitional basis to offeet income eamed from subdividing the land that othenwise would be taved at a 21% marginal tax rate

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