Transfers to investment companies: pitfalls of secs. 351 and 721.
The Tax Adviser - Vol. 38 Nbr. 8, August 2007
Velotta, Robert A.
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Transfers to investment companies: pitfalls of secs. 351 and 721.
In many instances, property can be contributed to an entity by its owners in exchange for ownership interests, without gain or loss being recognized on the contribution. For corporations, the general rule under Sec. 351(a) is that "no gain or loss shall be recognized if property is transferred to a corporation by one or more persons solely in exchange for stock in such corporation and immediately after the exchange such person or persons are in contr...
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