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Summary of Recommendations
Transfers to a Corporation of Property
Reorganizations Involving Exchanges of Equity for Equity
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acquired corporation's acquiring corporation adjusted basis amount assets basis and holding boot dividends boot received business combinations business purpose cash classes of stock conglomerate merger continuity of interest corporate business corporation in exchange Court current law debt determining dividend taxed earnings and profits economic Effects of Transaction extent fair market value feror gain or loss group of transferors holding period least 80 percent liabilities merger or consolidation nontaxable number of shares ownership parent partnership poration preferred stock property received property transferred realized gain recapture recognized gain recommendations reorganiza reorganization provisions Revenue Act section 351 securities received shareholder's shareholders Statements of tax stock or securities subsidiary substantially tax attributes tax avoidance tax deferral tax free tax law tax policy tax treatment taxable taxation taxpayer tion total number trans transferee corporation transferor's basis transferred property treated as boot type C reorganization U.S. Tax Cas voting power voting stock