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Section 351 Transactions
Posted on 10/12/15 at 9:28 pm
Posted on 10/12/15 at 9:28 pm
I have a corporate tax midterm coming up and wondering if anyone has any tips/shortcuts to 351 non recognition transactions. Trying to make some kind of flow chart but can't seem to set it up right. Any information that may have helped you will be appreciated.
1
Posted on 10/13/15 at 9:08 am to bicroundstic2008662
I don't know of any tips or shortcuts. Just remember that the transferor can only get back stock, and the transferor (or transferor group) must hold, after the event, both 80 percent of the voting power of voting classes of stock and 80 percent of outstanding shares of nonvoting classes of stock.
98 percent of the time I see it, which isn't too often anymore, is when a guy is doing business unincorporated and wants to later incorporate by trandferring assets to the company in exchange for stock.
The following is something I have in my research bookmarks, I've met the author before and he knows his stuff. It's a good overview of 351.
LINK
98 percent of the time I see it, which isn't too often anymore, is when a guy is doing business unincorporated and wants to later incorporate by trandferring assets to the company in exchange for stock.
The following is something I have in my research bookmarks, I've met the author before and he knows his stuff. It's a good overview of 351.
LINK
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