Transfers to Controlled Corporations: In General (Portfolio 758)


Howard Rothman


Kramer Levin Naftalis & Frankel LLP


Pamela M. Capps


Kramer Levin Naftalis & Frankel LLP


Barry Herzog


Kramer Levin Naftalis & Frankel LLP

Helayne Oberman Stoopack

Special Counsel

Kramer Levin Naftalis & Frankel LLP

At a glance

I. Introduction
II. Historical Development of § 351
III. Basic Requirements of § 351
IV. Receipt of Money or Other Property
V. The Receipt of Stock for Services
VI. Assumption of Liabilities
VII. Basis Computations in § 351 Transactions
VIII. Holding Period


Bloomberg Tax Portfolio, Transfers to Controlled Corporations: In General, discusses the tax considerations of transferring property to corporations controlled by the transferors.

Specifically, this Portfolio explains the basic requirements of a §351 exchange and analyzes the tax effects of: (1) a transferor's receipt of money or other property in addition to the stock of the transferee, (2) the transferor's provision of services in return for such stock, (3) the transferee's assumption of the transferor's liabilities (or acquisition of property from the transferor subject to a liability), and (4) the determination of the transferor's and transferee's basis and holding period for stock or property received by them.

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