In determining control for purposes of this section, the fact that any corporate transferor distributes part or all of the stock in the corporation which it receives in the exchange to its shareholders shall not be …

Feb 10, 2025 · Section 351 of the Internal Revenue Code (IRC) provides a tax benefit for certain transfers of property to a corporation. When property is transferred to a corporation in exchange for …

2 days ago · The Internal Revenue Code Section 351 provides a fundamental exception to the general rule that the exchange of property for stock constitutes a taxable event. This provision allows …

No gain or loss shall be recognized if property is transferred to a corporation by one or more persons solely in exchange for stock in such corporation and immediately after the exchange such person or …

Jan 1, 2024 · (1) Transfer of property to an investment company. --A transfer of property to an investment company. For purposes of the preceding sentence, the determination of whether a …

"Section 351 has been described as a deliberate attempt by Congress to facilitate the incorporation of ongoing businesses and to eliminate any technical constructions which are economically unsound."

As used in section 351, the phrase “one or more persons” includes individuals, trusts, estates, partnerships, associations, companies, or corporations (see section 7701 (a) (1)).

Sep 19, 2024 · A Section 351 transfer is a provision in the U.S. tax code that allows individuals or entities to transfer property to a corporation without recognizing gain or loss at the time of transfer, as …

Discover how IRC 351 enables tax-free property transfers to corporations. Avoid common pitfalls and optimize your startup's tax strategy with IRC 351.

(1) The general rule of section 351 does not apply, and consequently gain or loss will be recognized, where property is transferred to an investment company after June 30, 1967.