| 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... | |
| 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... | |
| 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... | |
| 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... | |
| 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 - 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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