Code of Federal Regulations: Containing a Codification of Documents of General Applicability and Future Effect as of December 31, 1948, with Ancillaries and IndexDivision of the Federal Register, the National Archives, 1972 - Administrative law |
From inside the book
Results 1-5 of 91
Page 5
... CORPORATE ORGANIZATIONS 1 . 351 Statutory provisions ; transfer to
corporation controlled ... 355 Statutory provisions ; distribution of stock and
securities of a controlled corporation . 1 . 355 – 1 Distribution of stock and
securities of ...
... CORPORATE ORGANIZATIONS 1 . 351 Statutory provisions ; transfer to
corporation controlled ... 355 Statutory provisions ; distribution of stock and
securities of a controlled corporation . 1 . 355 – 1 Distribution of stock and
securities of ...
Page 6
373 – 1 Nonrecognition of loss upon transfer of property of railroad corporation .
1 . 373 – 2 Property acquired by ... 381 ( c ) ( 1 ) - 2 Net operating loss carryovers
; two or more dates of distribution or transfer in the taxable year . 1 . 381 ( c ) ( 2 )
...
373 – 1 Nonrecognition of loss upon transfer of property of railroad corporation .
1 . 373 – 2 Property acquired by ... 381 ( c ) ( 1 ) - 2 Net operating loss carryovers
; two or more dates of distribution or transfer in the taxable year . 1 . 381 ( c ) ( 2 )
...
Page 19
A transfer of stock by the transferor , within the 10 - year period ending on the
date of the distribution , to a person whose stock would be attributable to the
transferor shall not be deemed to have as one of its principal purposes the
avoidance of ...
A transfer of stock by the transferor , within the 10 - year period ending on the
date of the distribution , to a person whose stock would be attributable to the
transferor shall not be deemed to have as one of its principal purposes the
avoidance of ...
Page 23
As to each person transferring stock , the amount received shall be treated as a
distribution of property under section 302 ( d ) , unless as to such person such
amount is to be treated as received in exchange for the stock under the terms of ...
As to each person transferring stock , the amount received shall be treated as a
distribution of property under section 302 ( d ) , unless as to such person such
amount is to be treated as received in exchange for the stock under the terms of ...
Page 24
If tion Y each have outstanding 100 shares of such distribution would have been
common stock . ... transferor ( $ 40 , 000 ) on the from the sale of his stock will be
treated as transfer . payment in exchange for this stock , provided Example ( 4 ) .
If tion Y each have outstanding 100 shares of such distribution would have been
common stock . ... transferor ( $ 40 , 000 ) on the from the sale of his stock will be
treated as transfer . payment in exchange for this stock , provided Example ( 4 ) .
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Common terms and phrases
accumulated acquiring corporation acquisition adjusted basis adoption amount applies assets assumed basis beginning capital carry carryovers close Code computed considered constructive controlled Corporation's date of distribution December 31 deduction Department described determined distribution or transfer distributor or transferor dividend earnings and profits effect election Example excess exchange extent facts fair market value Federal gain or loss graph hands holders holding illustrated immediately included increase Internal Revenue Code January Less liability limitation liquidation loss carryovers meaning method of accounting occurred operating loss outstanding stock ownership paid paragraph percent period person poration preceding prior provisions purchase pursuant qualified ration realized received recognized redemption referred regulations relating reorganization requirements respect rule section 306 securities Service share shareholder specific Statutory provisions subparagraph subsection taxable income taxable year ending term tion trade or business trans transaction transferor corporation treated tribution X Corporation
Popular passages
Page 111 - No gain or loss shall be recognized if stock or securities in a corporation a party to a reorganization are, in pursuance of the plan of reorganization, exchanged solely for stock or securities in such corporation or in another corporation a party to the reorganization.
Page 77 - June 22, 1954, and (2) Within the 12-month period beginning on the date of the adoption of such plan, all of the assets of the corporation are distributed in complete liquidation, less assets retained to meet claims, then no gain or loss shall be recognized to such corporation from the sale or exchange by it of property within such 12-month period. (b) Property defined — (1) In general. For purposes of subsection (a), the term "property...
Page 128 - If it were not for the fact that the property received In exchange consists not only of property permitted by such paragraph to be received without the recognition of gain, but also of other property or money, then the gain. If any, to the recipient shall be recognized, but In an amount not In excess of the sum of such money and the fair market value of such other property.
Page 141 - If the corporation receiving such other property or money does not distribute It In pursuance of the plan of reorganization, the gain. If any, to the corporation shall be recognized, but In an amount not In excess of the sum of such money and the fair market value of such other property so received, which Is not so distributed.
Page 45 - ... (b) Source of distributions. For the purposes of this Act every distribution is made out of earnings or profits to the extent thereof, and from the most recently accumulated earnings or profits.
Page 107 - No gain or loss shall be recognized If property is transferred to a corporation by one or more persons solely In exchange for stock or securities in such corporation, and Immediately after the exchange such person or persons are in control of the corporation...
Page 141 - If an exchange would be within the provisions of subsection (b) (1), (2), (3), or (5) of this section if it were not for the fact that the property received in exchange consists not only of property permitted by such paragraph to be received without the recognition of gain...
Page 128 - ... (B) as paid-in surplus or as a contribution to capital, then the basis shall be the same as it would be In the hands of the transferor, increased in the amount of gain or decreased in the amount of loss recognized to the transferor upon such transfer under the law applicable to the year in which the transfer was made.
Page 127 - No gain or loss shall be recognized If a corporation a party to a reorganization exchanges property, in pursuance of the plan of reorganization, solely for stock or securities in another corporation a party to the reorganization.
Page 138 - Permanent records in substantial form shall be kept by every taxpayer who participates in an exchange described in section 371 (b), showing the cost or other basis of the transferred property and the amount of stock or securities and other property or money received (including any liabilities assumed upon the exchange) , in order to facilitate the determination of gain or loss from a subsequent disposition of such stock or securities and other property received from the exchange.
Bibliographic information
| Title | Code of Federal Regulations: Containing a Codification of Documents of General Applicability and Future Effect as of December 31, 1948, with Ancillaries and Index |
| Contributor | United States. Office of the Federal Register |
| Publisher | Division of the Federal Register, the National Archives, 1972 |
| Original from | the University of California |
| Digitized | 2 Jul 2008 |
| Export Citation | BiBTeX EndNote RefMan |