The Code of Federal Regulations of the United States of AmericaU.S. Government Printing Office, 1990 The Code of Federal Regulations is the codification of the general and permanent rules published in the Federal Register by the executive departments and agencies of the Federal Government. |
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Common terms and phrases
5-percent shareholder acquiring corporation acquisition date adjusted basis adjusted grossed-up basis ADSP allocated amount assets capital loss carrybacks common stock computed Corporation's date of distribution December 31 deduction deemed sale described in section determined distribution or transfer distributor or transferor dividend domestic corporation earnings and profits election under section Example express election fair market value February 28 filed foreign corporation gain or loss graph intangible property inventories January June 30 loss carryovers loss corporation ment method of accounting operating loss ordinary income outstanding stock ownership change percent period poration pre-change preferred stock public group purposes pursuant qualified stock purchase quiring ration redemption reorganization respect ryovers section 338 election shares stock of Corporation stock or securities subdivision subparagraph target affiliate taxable income taxable year ending tier entity tion trade or business trans transaction transferor corporation treated U.S. person X Corporation
Popular passages
Page 249 - It were not for the fact that the property received In exchange consists not only of property permitted by such paragraph to be received without the recognition of gain, but also of other property or money, then the gain, If any, to the recipient 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.
Page 237 - ... more than 50 percent in value of the outstanding stock of which is owned by the same person. (2) Control. For purposes of this paragraph, control means the ownership of stock possessing at least 50 percent of the total combined voting power of all classes of stock entitled to vote or at least 50 percent of the total value of shares of all classes of stock of the corporation.
Page 55 - No gain or loss shall be recognized if stock or securities in a corporation a party to a reorganization are, in pursuance of the plan of reorganization, exchanged solely for stock or securities in such corporation or in another corporation a party to the reorganization.
Page 439 - ... such corporation has not continued to carry on a trade or business substantially the same as that conducted before...
Page 69 - ... possessing at least 80 percent of the total combined voting power of all classes of stock entitled to vote and the owner of at least 80 percent of the total number of shares of all other classes of stock (except nonvoting stock which is limited and preferred as to dividends...
Page 54 - ... in a distribution or exchange to which section 355 (or so much of section 356 as relates to section 355...
Page 273 - No gain or loss shall be recognized If a corporation a party to a reorganization exchanges property, in pursuance of the plan of reorganization, solely for stock or securities in another corporation a party to the reorganization.
Page 274 - ... then the basis shall be the same as it would be in the hands of the transferor, increased in the amount of gain or decreased in the amount of loss recognized to the transferor upon such transfer under the law applicable to the year in which the transfer was made...
Page 247 - No gain or loss shall be recognized if property is transferred to a corporation by one or more persons solely in exchange for stock or securities in such corporation, and immediately after the exchange such person or persons are in control of the corporation...
Page 56 - A stock dividend which was not subject to tax in the hands of the distributee because either it did not constitute income to him within the meaning of the sixteenth amendment to the Constitution or because exempt to him under section 115 (f) of the Revenue Act of 1934 (48 Stat. 712) or a corresponding provision of a prior Revenue Act, or section 305 of the Code.