Abstract- The provisions contained in IRC Sec 357 need to be very carefully examined so that the non-taxable position on the transfer of liabilities into a controlled corporation made below Sec 351 won't be jeopardized. In keeping with Sec 351, a transfer of residence to an organization in exchange for stocks is not going to set off the recognition of any obtain or decline provided which the recipient of your stocks will straight away attain control of the corporation.
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When corporate transferors are linked to transactions such as this, in contrast to persons, care should be taken. It can be done that in place of a tax-no cost transfer to your controlled Company, covered by Code §351, that what basically transpired was a corporate reorganization .
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Just have to have a actuality check on the right therapy of the transaction. My client is the greater part owner in 4 entities (C-Corps) that agreed to contributed assets and liabilities to a new C-Corp (NewCo). Many of the entities experienced liabilities in extra of property. Though, in accordance with § 351 and § 357, we taken care of this as tax totally free exchange and didn't report any acquire as being the four entities been given no cash proceeds and retained the two Command and retained Main liability to the transferred liabilities. I just got a get in touch with within the NewCo CPA saying they had been planning to report a action up in basis to FMV within the NewCo tax return and was questioning why we did not report a achieve.
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If you have 4 corporations combining have you been not hunting in direction of IRC sections that reference mergers, consolidations and acquisitions. If it requires the liquidation of entities and belongings/liabilities transferred to shareholders (attain/decline demanded) then a 351 incorporation would be used for The brand new entity. 357 challenges can exist in all sorts of formation. Comment