Question

Lance contributed investment property worth $507,500, purchased Five years ago for $312,500 cash, to Cloud Peak LLC in exchange for an 70 percent profits and capital interest in the LLC. Cloud Peak owes $380,000 to its suppliers but has no other debts.

Required information

A. What is Lance’s tax basis in his LLC interest?

B. What is Lance’s holding period in his interest?

C. What is Cloud Peak’s basis in the contributed property?

D. What is Cloud Peak’s holding period in the contributed property?

Answer 1

a. Lance's Tax basis in his LLC interest

= Basis of investment property + Shares in LLC debt

= $312,500 + ($380,000 * 70%)

= $312,500 + $266,000

= $578,500

Therefore, LLC common debt obligation treated as non-recourse debt, lance income allocation ratio is used to allocate a share of LLC debt to him

b. Lance holding period in his interest is 5 years. The holding period of the contributed assets "tacks onto" his partnership interest because Lance contributed a capital asset

c. Cloud Peak's basis in the contributed property is $312,500. Also, the carryover basis would be taken by the LLC in the contributed property

d. Cloud's Peak holding period in the contributed property is 3 years