What people are saying - Write a review
We haven't found any reviews in the usual places.
TABLE OF CAsEs _
TABLE or INTERNAL C0nE SEcT1oNs
TABLE or TREASURY REoULAT1oNs
128 other sections not shown
Other editions - View all
acquiring corporation acquisition adjusted basis agreement allocated alternative minimum tax amount apply assets attribution beneﬁt boot business purpose capital gains carryover cash classiﬁcation Code Commissioner common stock Congress contributed property contribution controlled corporation corporate level corporation’s debt deduction deﬁned deﬁnition determined distributing corporation dividend earnings and proﬁts election entity exchange fair market value ﬁnancial ﬁrst ﬁve held investment issued liability limited liquidation loan loss corporation merger nonrecognition ordinary income ownership change partner partnership interest payment percent petitioner preferred stock provides purchase pursuant qualiﬁed qualify received recognized redeemed redemption reﬂect regulations reorganization requirement result revenue procedure REVENUE RULING rules Safe Harbor satisﬁed Section 351 securities shareholder’s shareholders shares signiﬁcant speciﬁc statute statutory Subchapter subsidiary substantially target corporation tax avoidance tax consequences Tax Court tax purposes tax-free taxable income taxation taxpayer tion transaction transfer transferor treated treatment voting stock