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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. "
Regulations 86 Relating to the Income Tax Under the Revenue Act of 1934 - Page 174
by United States. Bureau of Internal Revenue, United States. Internal Revenue Service - 1935 - 466 pages
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The Internal Revenue Code of 1954: Hearings Before the Committee on ..., Part 1

United States. Congress. Senate. Committee on Finance - 1954 - 662 pages
...transaction it has established to the satisfaction of the Secretary or his delegate that the transaction is not in pursuance of a plan having as one of its...purposes the avoidance of Federal income taxes. The operation of this section is not clear, as is demonstrated by reference to the provisions with respect...
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Hearings, Reports and Prints of the Senate Committee on Finance, Parts 1-2

United States. Congress. Senate. Committee on Finance - 1954 - 1186 pages
...transaction it has established to the satisfaction of the Secretary or his delegate that the transaction is not in pursuance of a plan having as one of its...purposes the avoidance of Federal income taxes. The operation of this section is not clear, as is demonstrated by reference to the provisions with respect...
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Internal Revenue Bulletin

United States. Internal Revenue Service - 1954 - 1182 pages
...unless, prior to such exchange, it has been established to the satisfaction of the Commissioner that such exchange is not in pursuance, of a plan having as...principal purposes the avoidance of Federal income taxes. Section 39.112(g)-l of Regulations 118 provides in part that under the general rule, upon the exchange...
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Internal Revenue Bulletin

United States. Internal Revenue Service - 1955 - 1158 pages
...transfer it has been established to the satisfaction of tlie Secretary or bis 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. 1.1492-1. NONTAXABLE TRANSFERS. — (a) The tax imposed by iction 1491 does not apply: (1) If...
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Private Foreign Investment: Hearings Before the Subcommittee on Foreign ...

United States. Congress. House. Committee on Ways and Means, United States. Congress. House. Committee on Ways and Means. Subcommittee on Foreign Trade Policy - 1958 - 670 pages
...shall not he tax free unless, prior to the exchange, the Service has affirmatively ruled that "such exchange is not in pursuance of a plan having as one...principal purposes the avoidance of Federal income taxes." Up until a matter of 2 years ago, it appears that the Service did issue affirmative rulings under this...
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Foreign Investment Incentive Act: Hearings Before the Committee on Ways and ...

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...
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Foreign Investment Incentive Act: Hearings Before the Committee on Ways and ...

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....
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Internal Revenue Code of 1954, as Amended and in Force on January 3, 1961

United States, United States. Congress. Joint Committee on Internal Revenue Taxation - 1961 - 1208 pages
...such exchange, it has been established to the satisfaction of the Secretary or his delegate that such For purposes of this section, any distribution described in section 355 (or so much of section 356...
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Revenue Act of 1962: Hearings Before the Committee on Finance, United States ...

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...
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Legislative History of H.R. 8363: 88th Congress, the Revenue Act of 1964 ...

United States. Congress. House. Committee on Ways and Means - 1966 - 1120 pages
...the satisfaction of the Secretary or his delegate in advance of the liquidation that the liquidation is not in pursuance of a plan having as one of its...purposes the avoidance of Federal income taxes. The bill further provides that if a person received property in a liquidation of a foreign personal holding...
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