Mother corporation) or (B) a transfer by a corporation of all or a part of its assets to 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... Reports of the U.S. Board of Tax Appeals - Page 5by United States. Board of Tax Appeals - 1934Full view - About this book
| 1949 - 430 pages
...(B) a transfer by a corporation of all or a part of its assets to another corporation if immediately after the transfer the transferor or its stockholders...form, or place of organization, however effected. (d) Claim for this exemption will not be allowed unless, upon application, the Commissioner rules that... | |
| 1968 - 268 pages
...such dividends shall be treated as a distribution to which section 305 (b) (1) is applicable. (f ) The term "a party to a reorganization" includes a corporation resulting from a reorganization, and both corporations, in a transaction qualifying as a reorganization where one corporation acquires stock... | |
| 1966 - 468 pages
...transferee was not actively engaged in business at the time of the acquisition, and (3) After such transfer, the transferor or its stockholders, or both, are in control of the transferee during any part of the taxable year of the transferee, unless, (4) The transferee establishes... | |
| Wisconsin - 1982 - 1032 pages
...amended to read: 71.368 (2) PARTY TO A REORGANIZATION. For purposes of ss. 71.351 to 71.368, 4h« tef» "a party to a reorganization" includes a corporation resulting from a reorganization, and both corporations, in the case of a reorganization resulting from the acquisition by one corporation... | |
| Howard Abrams, Richard L. Doernberg - 1999 - 1044 pages
...reorganization included "a transfer by a corporation of all or a part of its assets if immediately after the transferor or its stockholders or both are in...corporation to which the assets are transferred." Accordingly, the transaction met the literal language of the then-applicable divisive reorganization... | |
| United States - 1939 - 780 pages
...assets to another corporation if immediately after the transfer the transferor or its shareholders or both are in control of the corporation to which the assets are transferred, or (D) a recapitalization, or (E) a mere change in identity, form, or place of organization, however effected.... | |
| CCH Tax Law Editors - 2008 - 2242 pages
...treated under section 305(c) as a deemed distribution to which sections 305(b)(4) and 301 apply. (f) The term "a party to a reorganization" includes a corporation resulting from a reorganization, and both corporations in a transaction See p. 20,601 for regulations not amended to reflect law changes... | |
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