Code Sections-MC1 Flashcards
(28 cards)
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
358(b)
basis of stock to shareholders
allocation of basis
358(d)(1)
basis of stock to shareholders
Assumption of liability
in general, treated as boot for basis adj.
358(d)(2)
basis of stock to shareholders
assumption of liabilities
exception for Sec. 357(c)(3)
362
basis of property to corporation: Carryover basis + gain recognized by shareholder
368(c)
control defined
1001
determination of gain and loss realized and recognized
1001 (a)
determination of gain and loss realized and recognized
computation of gain or loss
1001 (b)
determination of gain and loss realized and recognized
amount realized
1001 (c)
determination of gain and loss realized and recognized
gain or loss recognized
