Code Sections-MC1 Flashcards
351
treatment to transferor shareholders
351 (a)
treatment to transferor shareholders, general rule-nonrecognition
351 (b)
treatment to transferor shareholders
receipt of property- taxable boot
351 (c)
treatment to transferor shareholders
special rules
351 (d)
treatment to transferor shareholders
Contribution of services not considered property
351 (e)
treatment to transferor shareholders
exceptions
351 (f)
treatment to transferor shareholders
treatment to controlled corporation on distribution of boot property
351 (g)
treatment to transferor shareholders
nonqualified preferred stock treated as boot
357
corporation’s assumption of transferor shareholder’s liability
357 (a)
corporation’s assumption of transferor shareholder’s liability
General rule- not treated as boot for recognition purposes
357 (b)
corporation’s assumption of transferor shareholder’s liability
tax avoidance purpose- total amount of liabilities treated as boot
357 (c)
corporation’s assumption of transferor shareholder’s liability
Liabilities in excess of basis-triggers recognition
358
basis of stock to shareholders
358(a)(1)
basis of stock- qualified stock: substituted basis + gain recognized - boot received
358(a)(2)
basis of stock to shareholders
boot property received: FMV