WebThe amendments made by this section [amending this section and sections 355, 358, and 368 of this title] shall not apply to any distribution pursuant to a plan (or series of related transactions) which involves an acquisition described in section 355(e)(2)(A)(ii) of the … Please help us improve our site! Support Us! Search WebThe IRC of course is the final authority and accordingly 351 property includes anything qualifying as secret processes or formulas under IRC 861(a)(4) and IRC 862(a)(4), and any other secret information, in the general nature of a patented invention even if it is NOT technically patented in the patent law sense.
Sec. 362. Basis To Corporations - irc.bloombergtax.com
Webcontributions, corporate liquidations, and reorganizations (e.g., IRC 332, 351, 354, 355, 356, or 361) could receive tax-free treatment. However, when such nonrecognition transactions result in the transfer of property from a CFC to another FC, IRC 367(b) ... provide that if an exchanging S/H loses its status as a "section 1248 S/H" of the WebFeb 20, 2024 · Here the contribution might involve the target's assets rather than its equity if the buyer is concerned with the target's operating history and unknown liabilities.The corporate holding company formation equity rollover transaction (an IRC § 351 exchange). The IRC § 351 exchange is a common rollover transaction structure employed to take … list my car for sale free
Part I Section 351.–Transfer to Corporation …
WebAn investment company is defined under IRC Section 351 (e) (1) as a company holding at least 80% of its assets in stocks, securities, cash, notes, options, foreign currency, … WebSection 351(e) provides that the term stocks and securities includes stock, indebtedness, money and other equity interests. Section 351(e)(1)(B)(vi) provides that an interest in an entity will be treated as a stock or security if substantially all of the assets of such entity consist of stocks and securities as defined in § 351(e). Webexchange under section 351(a), treating the Class A stock as preferredstock other than nonqualified preferred stock within the meaning of section 351(g)(2)(A), and the Class B stock and Note as "other property" (i.e., boot). Taxpayer calculated the basis of the Note and the Class B stock as equal to their respective estimated fair market values. list my car online for sale