 | United States. Congress. House. Committee on Ways and Means - 1959 - 640 pages
...such exchange, it has been established to the satisfaction of the Secretary or his delegate that such exchange is not in pursuance of a plan having as one...principal purposes the avoidance of Federal income taxes. For purposes of this section, any distribution described in section 355 (or so much of section 356... | |
 | United States. Congress. House. Committee on Ways and Means - 1959 - 670 pages
...transfer it has been established to the satisfaction of the Secretary or his delegate that such transfer is not in pursuance of a plan having as one of its...principal purposes the avoidance of Federal income taxes." SEC. 4. EXTENSION OF WESTERN HEMISPHERE TRADE CORPORATION STATUS TO INTERNATIONAL TRADE CORPORATIONS.... | |
 | United States. Congress. Senate. Committee on Finance - 1962 - 986 pages
...go unrecognized, without first establishing to the satisfaction of the Treasury that the transaction is not in pursuance of a plan having as one of its...principal purposes the avoidance of Federal income taxes, and receiving a favorable ruling from the Treasury with respect to the transaction. Where patents have... | |
 | United States. Congress. House. Committee on Ways and Means - 1967 - 1374 pages
...Commissioner of Internal Revenue must give clearance by determining in advance that the transaction "is not in pursuance of a plan having as one of its...principal purposes the avoidance of Federal income taxes." Generally the Commissioner has been unwilling to grant such approval where there is an appreciable... | |
 | United States. Internal Revenue Service - 1979 - 664 pages
...even though it is made subject to a condition that, if there is a failure to obtain a determination that the exchange is not in pursuance of a plan having...principal purposes the avoidance of Federal income taxes, the transaction will not be consummated and to the extent possible the assets transferred will be returned.... | |
 | United States. Internal Revenue Service - 1979 - 644 pages
...not be considered to be a corporation unless it is established to the satisfaction of the Secretary that the exchange is not in pursuance of a plan having...principal purposes the avoidance of Federal income taxes. Section 7.367 (a)-l of the temporary regulations provides that a request for a ruling under section... | |
 | United States. Internal Revenue Service - 1974
...transaction, it is necessary, pursuant to section 367, that a ruling be obtained prior to the transaction that the exchange is not in pursuance of a plan having...principal purposes the avoidance of Federal income taxes. 26 CFR 1.367-1: Foreign corporations. Whether section 1248 of the Code applies to a situation in which... | |
 | United States. Internal Revenue Service - 1976 - 720 pages
...it has been established to the satisfaction of the Secretary or the Secretary's delegate that such exchange is not in pursuance of a plan having as one...principal purposes the avoidance of Federal income taxes. Section 1.367-1 of the Income Tax Regulations provides, in part, that such a planned transaction should... | |
 | United States. Internal Revenue Service - 1981 - 808 pages
...by regulations by the Secretary), it is established to the satisfaction of the Secretary that such exchange is not in pursuance of a plan having as one...principal purposes the avoidance of federal income taxes. The transfer of property (country A francs) by P (a domestic corporation) to S (its wholly owned foreign... | |
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... it has been established to the satisfaction of the Secretary or his delegate that such exchange is not in pursuance of a plan having as one of its principal purposes the avoidance of Federal income taxes. 
