Section 351 Of The Internal Revenue Code

Internal revenue code section 351.

Section 351 of the internal revenue code. Transfer to corporation controlled by transferor. Code unannotated title 26. Section 351 a is intended to apply to certain transactions where gain or loss may have accrued in a constitutional sense but where in a popular and economic sense there has been a mere change in the form of ownership and the taxpayer has not really cashed in on the theoretical gain or closed out a losing venture.

The amendments made by this section amending this section and sections 355 358 and 368 of this title shall not apply to any distribution pursuant to a plan or series of related transactions which involves an acquisition described in section 355 e 2 a ii of the internal revenue code of 1986 or in the case of the amendments made by. Internal revenue code 351. For a description of the requirements of 351 see text accompanying notes 14 18 infra.

Tained in 351 of the internal revenue code the code. 351 u s. No gain or loss shall be recognized if property is transferred to a corporation by one or more persons solely in exchange for stock in such corporation and immediately after the exchange such person or persons are in control as defined in section 368 c of the corporation.

351 a general rule.