Transfer of property from S Corp to a wholly owned LLC

E

Eli

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Hello all,

An S Corporation wishes to transfer real property to a newly formed WHOLLY OWNED LLC. Any thoughts as to the potential problems with recognition of gain upon distribution and disguised sale? To complicate the matter, the Corporation wishes to admit new shareholders. What if the single-member LLC admits new members (in exchange for cash contribution) and automatically becomes a partnership shortly after the transfer? Thank you all for your input!
 
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