Federal Tax

Transfers to Controlled Corporations: In General (Portfolio 758)

  • The Portfolio, Transfers to Controlled Corporations: In General, No. 758, discusses the tax considerations of transferring property to corporations controlled by the transferors.

Description

Tax Portfolio, Transfers to Controlled Corporations: In General, discusses the tax considerations of transferring property to corporations controlled by the transferors.

Specifically, this Portfolio explains the basic requirements of a exchange and analyzes the tax effects of: (1) a transferor’s receipt of money or other property in addition to the stock of the transferee, (2) the transferor’s provision of services in return for such stock, (3) the transferee’s assumption of the transferor’s liabilities (or acquisition of property from the transferor subject to a liability), and (4) the determination of the transferor’s and transferee’s basis and holding period for stock or property received by them.

Table of Contents

I. Introduction
II. Historical Development of § 351
III. Basic Requirements of § 351
IV. Receipt of Money or Other Property
V. The Receipt of Stock for Services
VI. Assumption of Liabilities
VII. Basis Computations in § 351 Transactions
VIII. Holding Period

rothman-howard-2015
Howard Rothman
Partner
Kramer Levin Naftalis & Frankel LLP
Pamela_Capps
Pamela M. Capps
Partner
Kramer Levin Naftalis & Frankel LLP
Barry-Herzog
Barry Herzog
Kramer Levin Naftalis & Frankel LLP
Helayne Oberman Stoopack
Helayne Oberman Stoopack
Special Counsel
Kramer Levin Naftalis & Frankel LLP
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