A transfer by a corporation of all or a part of its assets to another corporation if immediately after the transfer the transferor, or one or more of its shareholders (including persons who were shareholders immediately before the transfer), or any combination... Reports of the Tax Court of the United States - Page 76by United States. Tax Court - 1970Full view - About this book
| United States. Board of Tax Appeals - 1929 - 1592 pages
...another corporation if immediately after the transfer the transferor or its stockholders or both are in control of the corporation to which the assets are transferred, * * * But was there a transfer of assets by the bank to the trust company in the sense contemplated by the foregoing... | |
| United States - 1965 - 1110 pages
...its assets to another corporation if immediately after the transfer the transferor, or one or more of its shareholders (including persons who were shareholders...to which the assets are transferred are distributed ma transaction which qualifies under section 354, 355, or 356; (E) a recapitalization; or (F) a mere... | |
| 2006 - 836 pages
...in section 368(a)(l)(A), (B). or (C) or a reorganization described in section 368(a)(l)(D) in which stock or securities of the corporation to which the...in a transaction which qualifies under section 354 or 356 (whether the taxpayer is the acquirer or the target in the reorganization). (f) Documentation... | |
| 1969 - 268 pages
...Its assets to another corporation If Immediately after the transfer the transferor, or one or more of its shareholders (Including persons who were shareholders...before the transfer), or any combination thereof, Is hi control of the corporation to which the assets are transferred; but only If, in pursuance of the... | |
| 1999 - 532 pages
...determining- whether, immediately after the transfer of target assets, a shareholder of the transferor is in control of the corporation to which the assets are transferred within the meaning of section 368(a)(l)(D). (iv) Example. This paragraph (c)(3) is illustrated by the... | |
| 2000 - 586 pages
...determining whether, immediately after the transfer of target assets, a shareholder of the transferor is in control of the corporation to which the assets are transferred within the meaning of section 368(a)(l)(D). (iv) Example. The following example illustrates this paragraph... | |
| 1998 - 512 pages
...determining whether, immediately after the transfer of target assets, a shareholder of the transferor is in control of the corporation to which the assets are transferred within the meaning of section 368(a)(l)(D). (iv) Example. This paragraph (c)(3) is illustrated by the... | |
| Wisconsin - 1955 - 890 pages
...its assets to another corporation if immediately after the transfer the transferor, or one or more of its shareholders (including persons who were shareholders...distributed in a transaction which qualifies under s. 71.354, 71.355, or 71.356; 5. A recapitalization; or 6. A mere change in identity, form, or place... | |
| Wisconsin - 1955 - 850 pages
...its assets to another corporation if immediately after the transfer the transferor, or one or more of its shareholders (including persons who were shareholders...distributed in a transaction which qualifies under s. 71.354, 71.355, or 71.356; 5. A recapitalization; or 6. A mere change in identity, form, or place... | |
| United States. Congress. Joint Committee on Internal Revenue Taxation - 1955 - 152 pages
...immediately after the transfer, the transferor or one or more of its shareholders (including persons who are shareholders immediately before the transfer), or...the corporation to which the assets are transferred. This rule is applicable, however, only where (pursuant to the plan) stock or securities of the corporation... | |
| |