Recent amendments to Code sec. 357: Congress responds to "artificial basis creation"

Article Abstract:

The author discusses changes made to IRC section 357 which were intended to address corporate tax shelter transactions in the context of reorganizations and incorporations involving foreign corporations.

Foreign corporations, Incorporation

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Avoiding gain on excess liabilities in a Code sec. 351 exchange

Article Abstract:

Planning may avoid gain recognition on excess tax liabilities resulting from corporate assumption of liabilities attached to exchanged property which are in excess of the adjusted basis of the exchanged property in IRC section 351 transactions. Minimizing the liabilities or increasing properties' bases may be possible where avoiding section 367 gain recognition is not possible. Judicial precedent in cases such as Peracchi v. Commissioner in the US 9th Circuit Court of Appeals is unreliable but must be recognized.

Liabilities (Accounting), Stocks

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Bausch & Lomb doctrine finally passing away

Article Abstract:

This article concerns IRS proposed regulations which would change the tax treatment for certain "C" type corporate reorganizations under IRC section 368(a)(1)(C). The Bausch & Lomb Doctrine would no longer apply to cause gain recognition in cases where the voting stock percentage requirement is not met.

Corporate Tax Administration, Corporate taxes, Tax administration

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