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Old 04-11-2005, 09:46 PM
Thomas Healy
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Default Re: S-corp basis from debt

"Stuart A. Bronstein" <spamtrap[at]lexregia.com> wrote:
- quote -

> "anonymous" <k132052gh[at]yahoo.com> wrote:

> > My son (a non-shareholder full-time employee of the s-corp)
> > takes out a home equity loan and loans the proceeds to me. I
> > then loan it to my 100% owned s-corp. All loans equal or
> > exceed the AFR and are properly structured and documented.
> > Basis?


> No, loans do not affect basis.


The loans themselves have basis initially. If losses passed
through to the shareholder exceed the basis in stock (thus
driving the adjusted basis to zero), additional losses can
be claimed against the loan, reducing its basis. The tricky
part to this is what happens when the loan gets repaid, even
through monthly principal/interest payments, which are
likely in a well-drafted loan. Because the principal is paid
on a loan with reduced basis there will be a taxable gain
associated with each payment for the difference between
principal paid and basis. This will be short-term gain in
the first year of the loan. Once the loan is repaid, the
shareholder now has stock with basis higher than liquidation
value by the amount of loss allocated to the loan. This can
be recovered as a long-term capital loss only upon
termination of the corporation.

--
Tom Healy, CPA
Boulder, CO
Web: http://www.tomhealycpa.com

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  #1  
Old 04-11-2005, 04:37 PM
Stuart A. Bronstein
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Default Re: S-corp basis from debt

"anonymous" <k132052gh[at]yahoo.com> wrote:

- quote -

> My son (a non-shareholder full-time employee of the s-corp)
> takes out a home equity loan and loans the proceeds to me. I
> then loan it to my 100% owned s-corp. All loans equal or
> exceed the AFR and are properly structured and documented.
> Basis?


No, loans do not affect basis.

Stu

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Old 04-07-2005, 07:33 AM
anonymous
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Posts: n/a
Default Re: S-corp basis from debt

no comments? ok, how about this one then:

My son (a non-shareholder full-time employee of the s-corp)
takes out a home equity loan and loans the proceeds to me. I
then loan it to my 100% owned s-corp. All loans equal or
exceed the AFR and are properly structured and documented.
Basis?

<< -------------------------------------------------> << The Charter and the Guidelines for submitting > << messages to this newsgroup are at www.asktax.org > << ------------------------------------------------->
  #-1  
Old 03-25-2005, 06:04 AM
anonymous
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Posts: n/a
Default S-corp basis from debt

I own 100% of my S-Corp (in California). My spouse borrows
50K (in her name only but secured by our jointly-owned
personal residence) from the bank and the proceeds of loan
go into our joint personal checking account. I take the
money and deposit it in the S-corp bank account as a loan to
the S-Corp. Do I get basis from this transaction?

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