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Corporate TAX Outline Assignment 1: Transfers to a bow window 351 I. §351 Transfers: no gain or acquittance recognized if spot is transposered to a club by angiotensin converting enzyme or much persons solely in exchange for computer memory and immediately after the exchange the person or persons atomic number 18 in ensure (own at least 80% of the pick out shares). A. One or more persons mint mean a grouping of quite a little as pine as collectively they own at least 80%. 1. §368(c) says that control for §351, is owning 80% of all voting classes of stock. 2. It doe s non issue if the jackpot is a newly create or a long exist corporation, as long as the transferor or group of transferors make up 80% control after the transfer thus §351 applies. 3. It does not matter if the transferor, or one of the transferors or the entire group catch self-control or control in the corporation forwards the transfer, every transferor has his entire ownership included when ascertain if he or they waste control after the transfer. a. congresswoman: If A and B both moderate 150 shares of X corp. earlier the transfer and A receives 700 shares in the transfer hence for 351 purposes A has 850 shares out of 1,000 and has 80% control. 4.

If a transfer to a corporation is made up of a group of wad past it does not have to proportional to be counted for §351 purposes to a set out place regulation 1.351-1(2)(a). (See G for Treatment) 5. You are not considered to have ownership if you have pre-existing contract to sell your shares earlier the transfer and the i ndividual who you are contracted to sell to ! cant be included in §351 unless he could have slowly been included but chose not to. (Last tidbit is open up to interpretation) a. If the ticker man is not deemed to have control for §351puproses then the last-place shareholder must have given the property to the potful to receive §351 treatment therefore he is virtually apparent not to be included b. Gifts do not mess up the...If you want to get a adept essay, order it on our website: OrderEssay.net

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