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18 Cards in this Set
- Front
- Back
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Section 351
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No gain or loss will be recognized if property is transferred to a corp in exchange for stock and immediately after the exhanged these people are in control of the corp.
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1.351-1(a)
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Transfers of propert need to have 80 percent of the control, Need to be 10% or more to be legal.
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368 C
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Control means having 80% of the stock
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357
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1. Recieves property under 351
2. as part, another part to the exchanged assumes a liability of the taxpayer Then such assumption shall not be treated as money or other property and shall not prevent the exchanged from being with the provisions of sect 351 |
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358
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The basis of the prop permitted to be recieved under such sect without the recognition of gain or loss shall be the same as that of the prop exchanged
1. decreased by - the fair market value of any other prop (except money) recieved by the taxpayer - the amount of any money rec by the taxpayer - the amount of the loss to the taxpayer which was recognized on such exchange 2. increased by - amount which was treated as a div - amt of gain which was recog on such exchange |
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362 (a) Basis to corp
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The basis is the same as it would be in the hands of the transferor , increased in the amt of gain recog to the transferor on such transfer
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170 Charitable Contributions
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Charitable Contributions
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246
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Rules applying to deduction for dividends recieved
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248
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Organizational Expenditures
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55
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Alternative Min Tax Imposed
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267
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Losses, expenses, and interest with respect to transactions between related taxpayers
no deduction shall be allowed in respect of any loss from the sale or exchange of property, indirectly or directly |
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291
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Corporation section 1250 capital gain treatment
and ordinary income under 1245 |
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1245 gain
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Amt realized in excess of basis recovered is treated as ordinary gain
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1250
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Real property , amt in excess is ordinary income
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446
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Methods of accounting, cash, accrual
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448
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Limitations on use of cash method of accounting
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316 (a)
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Definition of dividends
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312
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Effect on earnings and profts
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