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Committees on Sales, Exchanges and Basis and Corporate Stockholder Relationships Tax Section Recommendation No. 1978-12: TO AMEND THE INTERNAL REVENUE CODE OF 1954 TO PROVIDE (1) THAT A CORPORATION BE TREATED AS HAVING A BASIS IN ITS UNISSUED OR TREASURY STOCK EQUAL TO THE FAIR MARKET VALUE OF SUCH STOCK AT THE TIME IT IS ISSUED OR TRANSFERRED; (2) THAT NO GAIN OR LOSS BE RECOGNIZED ON THE DISPOSITION BY A CONTROLLED CORPORATION OF STOCK OF ITS PARENT CORPORATION; (3) THAT A PARENT CORPORATION'S EXISTING BASIS IN THE STOCK OF ITS CONTROLLED SUBSIDIARY BE INCREASED TO REFLECT THE TRANSFEROR'S BASIS WHEN THE SUBSIDIARY ACQUIRES ASSETS OR STOCK FROM THE TRANSFEROR IN EXCHANGE FOR STOCK OF ITS PARENT, ISSUED OR TRANSFERRED PURSUANT TO A PLAN OF TAX-FREE REORGANIZATION; AND (4) THAT A PARENT CORPORATION'S BASIS IN THE STOCK OF A CORPORATION ACQUIRED BY MERGER OF THE PARENT'S CONTROLLED SUBSIDIARY INTO SUCH CORPORATION INCLUDE THE BASIS OF THE ACQUIRED CORPORATION IN ITS ASSETS, WHEN THE PARENT'S STOCK IS ISSUED OR TRANSFERRED AS CONSIDERATION PURSUANT TO THE PLAN OF TAX-FREE REORGANIZATION

Committees on Sales, Exchanges and Basis and Corporate Stockholder Relationships Tax Section Recommendation No. 1978-12: TO AMEND THE INTERNAL REVENUE CODE OF 1954 TO PROVIDE (1) THAT A CORPORATION BE TREATED AS HAVING A BASIS IN ITS UNISSUED OR TREASURY STOCK EQUAL TO THE FAIR MARKET VALUE OF SUCH STOCK AT THE TIME IT IS ISSUED OR TRANSFERRED; (2) THAT NO GAIN OR LOSS BE RECOGNIZED ON THE DISPOSITION BY A CONTROLLED CORPORATION OF STOCK OF ITS PARENT CORPORATION; (3) THAT A PARENT CORPORATION'S EXISTING BASIS IN THE STOCK OF ITS CONTROLLED SUBSIDIARY BE INCREASED TO REFLECT THE TRANSFEROR'S BASIS WHEN THE SUBSIDIARY ACQUIRES ASSETS OR STOCK FROM THE TRANSFEROR IN EXCHANGE FOR STOCK OF ITS PARENT, ISSUED OR TRANSFERRED PURSUANT TO A PLAN OF TAX-FREE REORGANIZATION; AND (4) THAT A PARENT CORPORATION'S BASIS IN THE STOCK OF A CORPORATION ACQUIRED BY MERGER OF THE PARENT'S CONTROLLED SUBSIDIARY INTO SUCH CORPORATION INCLUDE THE BASIS OF THE ACQUIRED CORPORATION IN ITS ASSETS, WHEN THE PARENT'S STOCK IS ISSUED OR TRANSFERRED AS CONSIDERATION PURSUANT TO THE PLAN OF TAX-FREE REORGANIZATION

  • 期刊名称The Tax Lawyer
  • 卷第31卷
  • 期第4期
  • 印刷ISSN0040-005X
  • 文件大小1366.11KB
  • 发表时间1978
  • DOI10.2307/20767904
  • 页码1487-1498
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