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" No gain or loss shall be recognized If property is transferred to a corporation by one or more persons solely In exchange for stock or securities in such corporation, and Immediately after the exchange such person or persons are in control of the corporation... "
Internal Revenue Cumulative Bulletin - Página 110
por United States. Internal Revenue Service - 1977
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Reports of the United States Tax Court, Volume 65

United States. Tax Court - 1975 - 1272 páginas
...more over the 14 yrs. than Milo E. Wilson. OPINION Section 351 provides, in part, that no gain shall be recognized if property is transferred to a corporation...the exchange such person or persons are in control of the corporation. 2 "Control" is defined for this purpose in section 368(c) as ownership of stock...
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United States Reports: Cases Adjudged in the Supreme Court at ..., Volume 398

United States. Supreme Court, John Chandler Bancroft Davis, Henry Putzel, Henry C. Lind, Frank D. Wagner - 1971 - 732 páginas
...in the present context. We deal with § 351 (a) of the Code which provides: "No gain or loss shall be recognized if property is transferred to a corporation...the exchange such person or persons are in control ... of the corporation." All that petitioners received from the corporations were securities equal...
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Reports of the United States Tax Court, Volume 89

United States. Tax Court - 1988 - 1400 páginas
...SEC. 351. TRANSFER TO CORPORATION CONTROLLED BY TRANSFEROR. (a) GENERAL RULE— No gain or loss shall be recognized if property is transferred to a corporation...the exchange such person or persons are in control las defined in section 368(c|) of the corporation. (b) RECEIPT OF PROPERTY— If subsection (a) would...
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The Code of Federal Regulations of the United States of America

1971 - 272 páginas
...corporation (including. In the case oí transfers made on or before June 30, 1967, an Investment company) by one or more persons solely In exchange for stock...persons are In control (as defined In section 368 (c) ) oí the corporation. For purposes of this section, stock or securities Issued for services shall...
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Reports of the United States Tax Court, Volume 56

United States. Tax Court - 1971 - 1470 páginas
...corporation (Including, In the case of transfers made on or before June 30, 1B67, an investment company) by one or more persons solely In exchange for stock...person or persons are In control (as defined In section 368(c)) of the corporation. For purposes of this section, utork or securities Issued for services shall...
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Code of Federal Regulations: Containing a Codification of Documents of ...

1971 - 616 páginas
...corporation (Including, In the case of transfers made on or before June 30, 1967, an Investment company) by one or more persons solely In exchange for stock...exchange such person or persons are In control (as denned In section 368(c) ) of the corporation. For purposes of this section, stock or securities Issued...
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Tax Conventions with Belgium, Finland, Trinidad and Tobago, and the ...

United States. Congress. Senate. Foreign Relations - 1971 - 186 páginas
...Revenue Code. Section 351 provides that no gain or loss shall be recognized if property is transfererd to a corporation by one or more persons solely in...immediately after the exchange such person or persons owns stock possessing at least 80% of the voting power and at least 80% of the total number of shares....
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Tax Conventions with Belgium, Finland, Trinidad and Tobago, and the ...

United States. Congress. Senate. Committee on Foreign Relations - 1971 - 196 páginas
...similar provision to domestic transactions and the revenue loss which such an extension might entail. solely in exchange for stock or securities in such...immediately after the exchange such person or persons owns stock possessing at least 80% of the voting power and at least 80% of the total number of shares....
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General Tax Reform (testimony from Administration and Public Witnesses ...

United States. Congress. House. Committee on Ways and Means - 1973 - 432 páginas
...is transferred to a corporation (including a regulated investment company as defined in Section 851) by one or more persons solely in exchange for stock...person or persons are in control (as defined in Section 368(c)) of the corporation. For the purposes of this section stock or securities issued for services...
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Code of Federal Regulations: Containing a Codification of Documents of ...

1973 - 310 páginas
...corporation (Including, In the case of transfers made on or before June 30, 1967, an Investment company) b; one or more persons solely In exchange for stock or...person or persons are In control (as defined In section 3C8(c) ) of the corporation. For purposes of this section, stock or securities issued for services...
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