The Code of Federal Regulations of the United States of AmericaU.S. Government Printing Office, 1972 - Administrative law The Code of Federal Regulations is the codification of the general and permanent rules published in the Federal Register by the executive departments and agencies of the Federal Government. |
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Page 10
... porate shareholders . If property ( other than money and other than the obliga- tions of the distributing corporation ) ... poration M had earnings and profits accumu- lated after February 28 , 1913 , in the amount of $ 26,000 , and it had ...
... porate shareholders . If property ( other than money and other than the obliga- tions of the distributing corporation ) ... poration M had earnings and profits accumu- lated after February 28 , 1913 , in the amount of $ 26,000 , and it had ...
Page 12
... poration X was $ 25 . The amount of the distribution determined under section 301 ( b ) is $ 80 . If A were a corporation , the amount of the distribution would be $ 5 ( assuming that sections 311 ( b ) and ( c ) , 1245 ( a ) , and 1250 ...
... poration X was $ 25 . The amount of the distribution determined under section 301 ( b ) is $ 80 . If A were a corporation , the amount of the distribution would be $ 5 ( assuming that sections 311 ( b ) and ( c ) , 1245 ( a ) , and 1250 ...
Page 13
... poration filing its income tax returns on a calendar year basis ) whose stock is 100 per- cent owned by corporation B ( a domestic corporation filing its income tax returns on a calendar year basis ) for the first time en- gaged in ...
... poration filing its income tax returns on a calendar year basis ) whose stock is 100 per- cent owned by corporation B ( a domestic corporation filing its income tax returns on a calendar year basis ) for the first time en- gaged in ...
Page 18
... poration to the corporation the interest in which has been terminated . ( d ) For the purpose of section 302 ( c ) ( 2 ) ( A ) ( i ) , a person will be considered to be a creditor only if the rights of such person with respect to the ...
... poration to the corporation the interest in which has been terminated . ( d ) For the purpose of section 302 ( c ) ( 2 ) ( A ) ( i ) , a person will be considered to be a creditor only if the rights of such person with respect to the ...
Page 24
... poration X to corporation Y. Since both before and after the transaction H owned directly and constructively 100 percent of the stock of corporation X , and assuming that section 302 ( b ) ( 1 ) is not applicable , the amount received ...
... poration X to corporation Y. Since both before and after the transaction H owned directly and constructively 100 percent of the stock of corporation X , and assuming that section 302 ( b ) ( 1 ) is not applicable , the amount received ...
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Common terms and phrases
accumulated earnings acquiring corporation adjusted basis applies common stock complete liquidation controlled corporation date of distribution December 31 described in section determined distributing corporation distribution or transfer distributor or transferor dividend carryover earnings and profits erty excess fair market value February 28 Federal feror corporation following examples gain or loss graph holders Internal Revenue Code January June 30 liability loss corporation method of accounting operating loss carryovers operating loss deduction outstanding stock ownership paragraph percent in value personal holding company plan of liquidation plan of reorganization poration postacquisition preceding taxable preferred stock provided in section provisions of section purchase pursuant quiring recognized redemption respect sale or exchange section 306 stock section 381 shareholder Statutory provisions stock of Corporation stock or securities subchapter subparagraph subsection taxable income taxable year beginning taxable year ending tion trade or business 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.