The Code of Federal Regulations of the United States of AmericaU.S. Government Printing Office, 1972 - Administrative law The Code of Federal Regulations is the codification of the general and permanent rules published in the Federal Register by the executive departments and agencies of the Federal Government. |
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Results 1-5 of 99
Page 8
... respect to certain plans of reorganization arising in 1954 . Making and filing of elections . 1.394 Statutory provisions ; effective date of part V , subchapter C , chapter 1 of the Code . 1.394-1 Effective date of part V of subchapter ...
... respect to certain plans of reorganization arising in 1954 . Making and filing of elections . 1.394 Statutory provisions ; effective date of part V , subchapter C , chapter 1 of the Code . 1.394-1 Effective date of part V of subchapter ...
Page 9
... respect to distributions of money and other property . ( a ) General . Section 301 provides the general rule for treatment of distribu- tions on or after June 22 , 1954 , of property by a corporation to a share- holder with respect to ...
... respect to distributions of money and other property . ( a ) General . Section 301 provides the general rule for treatment of distribu- tions on or after June 22 , 1954 , of property by a corporation to a share- holder with respect to ...
Page 12
... respect to their stock is within the terms of section 301 although it takes place at the same time as another trans- action if the distribution is in substance a separate transaction whether or not connected in a formal sense . This is ...
... respect to their stock is within the terms of section 301 although it takes place at the same time as another trans- action if the distribution is in substance a separate transaction whether or not connected in a formal sense . This is ...
Page 13
... respect to each of the portions computed under subdivi- sions ( i ) , ( ii ) , and ( iii ) of this subpara- graph , determine the proportionate part of the fair market value of the property attributable to such portion . The pro ...
... respect to each of the portions computed under subdivi- sions ( i ) , ( ii ) , and ( iii ) of this subpara- graph , determine the proportionate part of the fair market value of the property attributable to such portion . The pro ...
Page 14
... respect to the distribution and since the fair market value of the property ( $ 100,000 ) exceeds the adjusted basis of the property in A's hands ( $ 40,000 ) , the amount of the distribution taken into account under section 301 ( c ) ...
... respect to the distribution and since the fair market value of the property ( $ 100,000 ) exceeds the adjusted basis of the property in A's hands ( $ 40,000 ) , the amount of the distribution taken into account under section 301 ( c ) ...
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Common terms and phrases
accumulated earnings acquiring corporation adjusted basis applies common stock complete liquidation controlled corporation date of distribution December 31 described in section determined distributing corporation distribution or transfer distributor or transferor dividend carryover earnings and profits erty excess fair market value February 28 Federal feror corporation following examples gain or loss graph holders Internal Revenue Code January June 30 liability loss corporation method of accounting operating loss carryovers operating loss deduction outstanding stock ownership paragraph percent in value personal holding company plan of liquidation plan of reorganization poration postacquisition preceding taxable preferred stock provided in section provisions of section purchase pursuant quiring recognized redemption respect sale or exchange section 306 stock section 381 shareholder Statutory provisions stock of Corporation stock or securities subchapter subparagraph subsection taxable income taxable year beginning taxable year ending tion trade or business transaction transferor corporation treated tribution X Corporation
Popular passages
Page 111 - No gain or loss shall be recognized if stock or securities in a corporation a party to a reorganization are, in pursuance of the plan of reorganization, exchanged solely for stock or securities in such corporation or in another corporation a party to the reorganization.
Page 77 - June 22, 1954, and (2) Within the 12-month period beginning on the date of the adoption of such plan, all of the assets of the corporation are distributed in complete liquidation, less assets retained to meet claims, then no gain or loss shall be recognized to such corporation from the sale or exchange by it of property within such 12-month period. (b) Property defined — (1) In general. For purposes of subsection (a), the term "property...
Page 128 - If it were not for the fact that the property received In exchange consists not only of property permitted by such paragraph to be received without the recognition of gain, but also of other property or money, then the gain. If any, to the recipient shall be recognized, but In an amount not In excess of the sum of such money and the fair market value of such other property.
Page 141 - If the corporation receiving such other property or money does not distribute It In pursuance of the plan of reorganization, the gain. If any, to the corporation shall be recognized, but In an amount not In excess of the sum of such money and the fair market value of such other property so received, which Is not so distributed.
Page 45 - ... (b) Source of distributions. For the purposes of this Act every distribution is made out of earnings or profits to the extent thereof, and from the most recently accumulated earnings or profits.
Page 107 - No gain or loss shall be recognized If property is transferred to a corporation by one or more persons solely In exchange for stock or securities in such corporation, and Immediately after the exchange such person or persons are in control of the corporation...
Page 141 - If an exchange would be within the provisions of subsection (b) (1), (2), (3), or (5) of this section if it were not for the fact that the property received in exchange consists not only of property permitted by such paragraph to be received without the recognition of gain...
Page 128 - ... (B) as paid-in surplus or as a contribution to capital, then the basis shall be the same as it would be In the hands of the transferor, increased in the amount of gain or decreased in the amount of loss recognized to the transferor upon such transfer under the law applicable to the year in which the transfer was made.
Page 127 - No gain or loss shall be recognized If a corporation a party to a reorganization exchanges property, in pursuance of the plan of reorganization, solely for stock or securities in another corporation a party to the reorganization.
Page 138 - Permanent records in substantial form shall be kept by every taxpayer who participates in an exchange described in section 371 (b), showing the cost or other basis of the transferred property and the amount of stock or securities and other property or money received (including any liabilities assumed upon the exchange) , in order to facilitate the determination of gain or loss from a subsequent disposition of such stock or securities and other property received from the exchange.