 | United States - 1953 - 1744 pages
...appears that (A) any corporation which is a party to such reorganization was not intended to continue the purpose (c) Gain from exchanges not solely in kind. (1) If an exchange would be within the provisions of subsection... | |
 | 2000 - 586 pages
...corporate business purpose or purposes for a transaction are evidence that the transaction was not used principally as a device for the distribution of earnings and profits within the meaning of section 355(a)(l)(B). See paragraph (d)(3)(ii) of this section. (5) Examples.... | |
 | 2002 - 596 pages
...corporate business purpose or purposes for a transaction are evidence that the transaction was not used principally as a device for the distribution of earnings and profits within the meaning of section 355(a)(l)(B). See paragraph (d)(3)(ii) of this section. (5) Examples.... | |
 | 2001 - 580 pages
...corporate business purpose or purposes for a transaction are evidence that the transaction was not used principally as a device for the distribution of earnings and profits within the meaning of section 355(a)(l)(B). See paragraph (d)(3)(ii) of this section. (5) Examples.... | |
 | United States, Walter Elbert Barton - 1953 - 708 pages
...appears that (A) any corporation which is a party to such reorganization was not intended to continue the active conduct of a trade or business after such reorganization,...of any corporation a party to the reorganization. Sec. 112 (b) (ะจ, IRC, supra, added to IRC by Sec. 317 (a). RA of 1951. Sec. 317 (c) of said Act makes... | |
 | United States. Internal Revenue Service - 1964 - 744 pages
...corporation. However, section 355 (a) ( 1 ) ( B ) of the Code provides that the transaction must not be used principally as a device for the distribution of earnings and profits of the distributing corporation or the controlled corporation or both. Although the parent corporation... | |
 | United States. Congress. Senate. Committee on Finance - 1954 - 656 pages
...were not intended to continue the active conduct of a trade or business, or the spun-off corporation was used principally as a device for the distribution of earnings and profits. These provisions, of course, involved matters of judgment which the bill attempts to eliminate. The... | |
 | United States. Congress. House. Committee on Banking and Currency - 1955 - 664 pages
...appears that (A) any corporation which is a party to such reorganization was not intended to continue the active conduct of a trade or business after such reorganization,...used principally as a device for the distribution of eimiinis and profits to the shareholders of any coriioration a party to the reorganization." It thus... | |
 | United States. Internal Revenue Service - 1955 - 1158 pages
...are already in process, is generally considered sufficient evidence that the distribution of stock was used principally as a device for the distribution of earnings and profits of the distributing corporation. The purpose of the requirement that the transaction not be used principally... | |
 | United States. Internal Revenue Service - 1957 - 836 pages
...corporation owned by the same stockholder and his wife, the transaction was considered to be one which was used principally as a device for the distribution of earnings and profits of the distributing corporation within the purview of section 355(a)(l)(B) of the Code. Therefore,... | |
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... device for the distribution of earnings and profits to the shareholders of any corporation a party to the reorganization. 
