Transfers to Controlled Corporations: Related Problems (Portfolio 759)

Description

Bloomberg Tax Portfolio, Transfers to Controlled Corporations: Related Problems, discusses the relationship between §351 and other provisions of the Code.

Specifically, this Portfolio analyzes the relationship between §351 and other provisions of the Code, and (1) compares the various methods of transferring property to a controlled corporation, (2) describes the effect of, and problems arising from, the incorporation of a sole proprietorship, partnership, or limited liability company, (3) discusses the problems related to a §351 transaction involving foreign transferees or transferors, investment companies, and bank holding companies, (4) analyzes the relationship between §351 and the reorganization provisions of the Code, and (5) sets forth the recordkeeping, filing, and ruling request requirements of a §351 transaction.

Table of Contents

I. Comparison of Methods of Transferring Property to Controlled Corporations
II. Intentional Avoidance of Nonrecognition Treatment Under § 351
III. Incorporation of an Active Business
IV. Section 351 and the Reorganization Provisions
V. Transfers to Investment Companies – §351(e)
VI. Transfers by U.S. Persons to Foreign Corporations
VII. Transfers by Foreign Persons
VIII. Filing and Recordkeeping Requirements; Ruling Requests