Search results
- Sec. 356 (a) provides that if the nonrecognition rules under Sec. 354 or 355 would apply to an exchange but for the fact that the property received in the exchange consists of property other than stock or securities (i.e.,boot), then the gain, if any, to the recipient shall be recognized to the extent of the sum of money received and/or the fair market value (FMV) of any other property received.
www.thetaxadviser.com › issues › 2016Gain and Loss Recognition Under Sec. 356(c) - The Tax Adviser
the property received in the exchange or distribution consists not only of property permitted by section 354 or 355 to be received without the recognition of gain or loss, but also of other property or money, then no loss from the exchange or distribution shall be recognized.
- Uscode - 26 USC 358
(1) In general. Under regulations prescribed by the...
- Uscode - 26 USC 367
26 U.S. Code § 367 - Foreign corporations. If, in connection...
- Uscode - 26 USC 358
People also ask
Does Section 355 apply to a distribution?
Does Section 354 apply to an exchange or distribution?
What is a reorganization without a loss under Section 361?
I.R.C. § 356 (c) (2) —. the property received in the exchange or distribution consists not only of property permitted by section 354 or 355 to be received without the recognition of gain or loss, but also of other property or money, then no loss from the exchange or distribution shall be recognized.
(1) In general. Under regulations prescribed by the Secretary, the basis determined under subsection (a) (1) shall be allocated among the properties permitted to be received without the recognition of gain or loss. (2) Special rule for section 355.
26 U.S. Code § 367 - Foreign corporations. If, in connection with any exchange described in section 332, 351, 354, 356, or 361, a United States person transfers property to a foreign corporation, such foreign corporation shall not, for purposes of determining the extent to which gain shall be recognized on such transfer, be considered to be a ...
Jul 1, 2022 · U.S. corporations regularly transfer property to subsidiaries in transactions that qualify for tax - deferred treatment for U.S. federal income tax purposes (see, e.g., Secs. 351 and 354).
Feb 21, 2006 · Section 356 generally applies if section 354 would apply to an exchange but for the fact that the property received in the exchange consists not only of property permitted by section 354 to be received without the recognition of gain but also of other property or money.
The statutory period for the assessment of any deficiency attributable to a corporation failing to be a family-owned corporation shall not expire before the expiration of 3 years after the date the Secretary is notified by the corporation (in such manner as the Secretary may prescribe) of such failure, and such deficiency may be assessed before ...
