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Tax Treatment of IRC 351 Nonrecognition Transactions aka Corporate Reorganizations

Posted on June 6, 2013 by John R. Dundon II, EA — No Comments ↓

Check out the following 5 lessons I learned this week regarding IRC 351 nonrecognition transactions: 1. The basis assigned to stock received generally is the same as the basis in the property transferred to the corporation. If however you also…

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Posted in 1031 Exchange, 1231 Exchange, Basis, Capital Gain, Capital Loss, Like/Kind Exchange, Sub-chapter S, Uncertain Tax Position

Tax Treatment of Liabilities Assumed by a Corporation IRC 357 – What is Boot?

Posted on June 4, 2013 by John R. Dundon II, EA — No Comments ↓

According to IRC 357(a) if property transferred to a corporation in an IRC 351 nonrecognition transaction is subject to a liability, the assumption of that liability by the corporation generally is not treated as taxable "boot" for purposes of determining the amount…

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Posted in Abusive Tax Shelter, Basis, Boot, Capital Gain, Capital Loss, Cash Transaction, Deductible Expense, Distributions, Tax Guidance & Preparation
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