361 Irc. See internal revenue code (irc) section 361—nonrecognition of gain. In a transfer to which section 361 (relating to nonrecognition of gain or loss to corporations) applies, but only if the transfer is in connection with a reorganization described in.
See internal revenue code (irc) section 361—nonrecognition of gain. § 367 (a) (1) general rule —.
See Internal Revenue Code (Irc) Section 361—Nonrecognition Of Gain.
Under irc § 381(a), the tax attribute carryover rules apply to any transaction to which irc § 361 applies.
§ 367 (A) Transfers Of Property From The United States.
Section 367(a)(1) generally provides that if a u.s.
To Address This Concern, Sec.
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The Amendments Made By This Section [Amending This Section And Section 361 Of This Title].
Except as provided in regulations prescribed by the secretary, if a united states person transfers any intangible property to a foreign corporation in an exchange described in.
In A Transfer To Which Section 361 (Relating To Nonrecognition Of Gain Or Loss To Corporations) Applies, But Only If The Transfer Is In Connection With A Reorganization Described In.
§ 361(b)(1)(a) property distributed — if the corporation receiving such other property or money distributes it in pursuance of the plan of reorganization, no gain to the.
367(A)(1) Provides That A Transfer Of Property From A U.s.