Webgain shall be recognized currently, or amounts included in gross income currently as a … WebCode §361(a) and (b). 18. Code §362(b). 19. Code §361(c). 20. Code §356(a). Note that all or a portion of the gain recognized may be rechar - acterized as a dividend. Code §356(a)(2). 21. Code §358. Acquiror Acquiror Shareholders. Cash & Acquiror . Shares Surrender . Target Shares. Target Target Shareholders. 2 1. Cash & Acquiror Shares ...

The US Corporate Reorganization Rules - Asena Advisors

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Tax 101: Corporate Reorganizations Part I – Types A&B

Webwhich to view the application of section 361 in the divisive reorganization context. Under section 361(a), a corporation that is a party to a reorganization will not recognize gain or loss upon the receipt of stock or securities in another corporation that is a party to the reorganization. If a corporation receives mone y or other property in Webin determining applicable earnings, the amount taken into account by reason of being described in paragraph (2) of section 316 (a) shall be the portion of the amount so described which is allocable (on a pro rata basis) to the part of such year during which the corporation is a controlled foreign corporation. WebJan 1, 2024 · Internal Revenue Code § 361. Nonrecognition of gain or loss to corporations; treatment of distributions on Westlaw FindLaw Codes may not reflect the most recent version of the law in your jurisdiction. Please verify the status of the code you are researching with the state legislature or via Westlaw before relying on it for your legal … population viability definition