IRC 351 Archives - John R. Dundon II, Enrolled Agent
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IRC 351 Tag

07 Jun

Posted at 00:00h in 1031 Exchange, 1231 Exchange, Basis, Capital Gain, Capital Loss, Like/Kind Exchange, Sub-chapter S, Uncertain Tax Position

Check out the following 5 lessons I learned this week regarding IRC 351 nonrecognition transactions: 1. The basis assigned to stock received generally is the same as the basis in the property transferred to the corporation. If however you also receives boot from the corporation your...

04 Jun

Posted at 00:00h in Abusive Tax Shelter, Basis, Boot, Capital Gain, Capital Loss, Cash Transaction, Deductible Expense, Distributions, Tax Guidance & Preparation

According to IRC 357(a) if property transferred to a corporation in an IRC 351 nonrecognition transaction is subject to a liability, the assumption of that liability by the corporation generally is not treated as taxable "boot" for purposes of determining the amount of any taxable gain on...

03 Jun

Posted at 00:00h in 351, Capital Gain, Capital Loss, Corporation, Like/Kind Exchange, Tax Guidance & Preparation

If property is transferred to a corporation by one or more people solely in exchange for stock in the corporation and immediately after the exchange the person or people engaged in the exchange are in control of the corporation then generally speaking subject of course...

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