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, 1962 - Administrative law |
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Common terms and phrases
accumulated earnings acquiring cor acquiring corporation Administration amended by T.D. amount realized assets Bankruptcy Act basis Bureau calendar capital gain capital loss carryovers close of June complete liquidation computed corporate acquisitions Corporation's taxable date of distribution December 31 deductible under section deficit in accumulated Department depreciation distribution or transfer distributor or trans distributor or transferor dividend carryover dividends paid deduction earnings and profits election Example excess contributions exchange expendi feror corporation filed gain or loss gross income ings and profits Internal Revenue Code June 22 June 30 liability National Shipping Authority nonrecognition paragraph payment poration property or money provisions of section pursuant quiring railroad corporation received respect section 381 section 404 section 615 section 77 Service share standard deduction Statutory provisions stock of corporation subparagraph Subtitle tax imposed taxable income taxable year ending taxpayer tion transaction transferor corporation treated tributor or transferor Y Corporation
Popular passages
Page xxiv - Amounts received under a life insurance contract paid by reason of the death of the insured, whether in a single sum or otherwise (but if such amounts are held by the insurer under an agreement to pay interest thereon, the interest payments shall be included in gross income); (2) ANNUITIES, ETC.
Page xx - 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 xx - ... showing the cost or other basis of the transferred property and the amount of stock or securities and other property or money received...
Page xxiv - If, taking into consideration the nature of the liability and the circumstances in the light of which the arrangement for the assumption or acquisition was made, it appears that the principal purpose of the taxpayer with respect...
Page 8 - ... by the distributor or transferor corporation, the acquiring corporation shall be treated as the distributor or transferor corporation as of its first taxable year which begins after the date of distribution or transfer.
Page 6 - For this purpose, the basis of the property in the hands of the distributor or transferor corporation shall be the adjusted basis provided in section 1011 for the purpose of determining gain on the sale or other disposition of such property.
Page xxiv - ... if the sum of the amount of the liabilities assumed, plus the amount of the liabilities to which the property is subject, exceeds the total of the adjusted basis of the property transferred pursuant to such exchange, then such excess shall be considered as a gain from the sale or exchange of a capital asset or of property which is not a capital asset, as the case may be.
Page xxvii - The application of subparagraph (1) of this paragraph may be illustrated by the following examples, in which it is assumed that the plans are not "qualified...
Page xxiv - ... in which he receives a distribution in complete liquidation — (1) The amount realized by such shareholder on the distribution shall be increased by his proportionate share of the amount by which the tax imposed by this subtitle on such corporation would have been reduced if...
Page xxiv - Assume that corporation S, having only common stock outstanding, is owned 90 percent by corporation P (which has owned the S stock for 3 years) and 10 percent by individual A (a calendar year taxpayer), and that the sole assets of corporation S are two buildings, each having a fair market value of $100,000 and a basis to the corporation of $50,000. Assume further that A's basis for his stock is $10,000. On August 1, 1958, corporation S adopts a plan of complete liquidation. On September 1, 1958,...