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For purposes of paragraph (1), any transfer of the other property or money received in the exchange by the corporation to its creditors in connection with the reorganization shall be treated as a distribution in pursuance of the plan of reorganization.
Prior to amendment, section related to whether gain or loss was recognized if corporation which was party to reorganization exchanged property, pursuant to plan of reorganization, for stock or securities in another corporation which was party to the reorganization or for other property or money.
(1) In general Except as provided in regulations prescribed by the Secretary, if a United States person transfers any intangible property to a foreign corporation in an exchange described in section 351 or 361 —
Aug 12, 2024 · See Internal Revenue Code (IRC) Section 361—nonrecognition of gain or loss to corporations; treatment of distributions. Read the full Sec. 361 on Tax Notes.
in a transfer to which section 361 (relating to nonrecognition of gain or loss to corporations) applies, but only if the transfer is in connection with a reorganization described in subparagraph (A), (C), (D), (F), or (G) of section 368 (a) (1),
Jan 1, 2024 · Read this complete 26 U.S.C. § 361 - U.S. Code - Unannotated Title 26. Internal Revenue Code § 361. Nonrecognition of gain or loss to corporations; treatment of distributions on Westlaw. FindLaw Codes may not reflect the most recent version of the law in your jurisdiction.
Jul 1, 2022 · To address this concern, Sec. 367 (a) (1) provides that a transfer of property from a U.S. person to a foreign corporation (an outbound transfer) in an exchange described in Sec. 332, 351, 354, 356, or 361 is treated as not made to a corporation for purposes of determining whether the U.S. person recognizes gain on the transfer.
Sec. 361 (a) states that no gain or loss to a corporation will be recognized if that corporation is a party to a reorganization and exchanges property solely for stock of another corporation involved in the reorganization.
Apr 14, 2021 · This report analyzes the potential scope of agency authority under Section 361. It begins by providing background regarding Section 361’s text and enactment, followed by an overview of the legal principles relevant to analyzing the provision’s scope.
No gain or loss shall be recognized to a corporation if such corporation is a party to a reorganization and exchanges property, in pursuance of the plan of reorganization, solely for stock or securities in another corporation a party to the reorganization.
