Summary- The provisions contained in IRC Sec 357 must be meticulously examined so that the non-taxable standing from the transfer of liabilities to a managed Company made underneath Sec 351 will not be jeopardized. In accordance with Sec 351, a transfer of property to a corporation in exchange for shares will not likely trigger the recognition of any gain or loss provided the recipient from the stocks will instantly attain Charge of the corporation.

Roland and bbrown - I stand corrected, nonetheless- would not the obtain be precisely the same and will not likely The brand new CPA need the for each asset/for each Observe payable facts? Sorry with the confusion and glad you and Jon are giving responses on this thread. Remark

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" I think this concept would apply to every in the four transferor corps, not to the put together quantities for all four transferor corps taken in general.

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11(b). Throughout the reporting interval did the labor organization Have got a subsidiary Group as defined in Area X of these Guidance?

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Okay, so it looks like a get must be acknowledged. Now, 1 further more concern. The Firms transferring all of their belongings and liabilities had been over the cash basis of accounting.

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