The Code of Federal Regulations of the United States of AmericaU.S. Government Printing Office, 1975 The Code of Federal Regulations is the codification of the general and permanent rules published in the Federal Register by the executive departments and agencies of the Federal Government. |
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The Code of Federal Regulations of the United States of America ..., Volume 1 Visualização integral - 1939 |
The Code of Federal Regulations of the United States of America ..., Volume 3 Visualização integral - 1939 |
Palavras e frases frequentes
accumulated earnings acquiring corporation adjusted basis assets capital loss classes of stock common stock complete liquidation controlled corporation date of distribution December 31 depreciation described in section determined distributing corporation distribution or transfer distributor or transferor dividend carryover earnings and profits election erty excess fair market value Federal feror corporation following examples gain or loss graph holders Internal Revenue Code January June 30 liability loss corporation method of accounting method of taking operating loss carryovers outstanding stock ownership paragraph percent in value plan of liquidation poration postacquisition preferred stock provided in section provisions of section purchase purposes of section pursuant quiring recognized referred respect rules sale or exchange section 301 applies section 306 stock shareholder Statutory provisions stock of Corporation stock or securities subchapter subparagraph subsection taxable income taxable year beginning taxable year ending tion trade or business transaction transferor corporation treated tribution X Corporation
Passagens conhecidas
Página 144 - ... (2) If a distribution made in pursuance of a plan of reorganization is within the provisions of paragraph (1) of this subsection but has the effect of the distribution of a taxable dividend, then there shall be taxed as a dividend to each distributee such an amount of the gain recognized under paragraph (1) as is not in excess of his ratable share of the undistributed earnings and profits of the corporation accumulated after February 28, 1913. The 'remainder, if any, of the gain recognized under...
Página 134 - In exchange consists not only of property permitted by such paragraph to be received without the recognition of gain, but also of other property or money, then the gain, If any, to the recipient shall be recognized, but In an amount not In excess of the sum of such money and the fair market value of such other property.
Página 154 - ... the acquisition by one corporation, in exchange solely for all or a part of its voting stock...
Página 81 - ... possessing at least 80 percent of the total combined voting power of all classes of stock entitled to vote and the owner of at least 80 percent of the total number of shares of all other classes of stock (except nonvoting stock which is limited and preferred as to dividends...
Página 137 - ... (2) Non pro rata distributions, etc. — Paragraph (1) shall be applied without regard to the following: (A) whether or not the distribution is pro rata with respect to all of the shareholders of the distributing corporation, O Copyright 1958 by I'rentlce Hall, Inc.
Página 49 - For purposes of subsection (a), the term "property" does not include — (A) stock in trade of the corporation, or other property of a kind which would properly be included in the inventory of the corporation if on hand at the close of the taxable year...
Página 266 - ... such corporation has not continued to carry on a trade or business substantially the same as that conducted before...
Página 69 - For purposes of this subtitle, the term "dividend" means any distribution of property made by a corporation to Its shareholders — (1) Out of Its earnings and profits accumulated after February 28, 1913, or (2) Out of Its earnings and profits of the taxable year (computed as of the close of the taxable year without diminution by reason of any distributions made during the taxable year), without regard to the amount of the earnings and profits at the time the distribution was made.
Página 152 - ... (B) as paid-in surplus or as a contribution to capital, then the basis shall be the same as it would be in the hands of the transferor, increased in the amount of gain or decreased in the amount of loss recognized to the transferor upon such transfer under the law applicable to the year in which the transfer was made.
Página 67 - ... was recognized by law, or (2) if the distribution was not subject to tax in the hands of such distributee because it did not constitute income to him within the meaning of the Sixteenth Amendment to the Constitution or because exempt to him under section 115 (f ) of the Revenue Act of 1934, 48 Stat. 712, or a corresponding provision of a prior Revenue Act. As used in this subsection the term "stock or securities" includes rights to acquire stock or securities.