26 U.S. Code § 351 - Transfer to corporation controlled by transferor
In determining control for purposes of this section, the fact that any corporate transferor distributes part or all of the stock in the corporation which it receives in the exchange to its shareholders shall not be …
Section 351(a) provides 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 …
Understanding Section 351: Asset Transfers and Requirements for Tax ...
Feb 10, 2025 · What is Section 351? Under IRC Section 351, when a person transfers property to a corporation in exchange for stock, the transfer is tax-deferred, meaning no immediate gain or loss is …
Code Section 351 (Transfer to corporation controlled by transferor)
1 day ago · Under IRC section 351 (a), no gain or loss is recognized when property is transferred to a corporation by a person solely in exchange for stock in that corporation and that person is in control …
26 CFR 1.351-1 -- Transfer to corporation controlled by transferor.
(1) The general rule of section 351 does not apply, and consequently gain or loss will be recognized, where property is transferred to an investment company after June 30, 1967.
Understanding Section 351 Transfers to a Corporation
Jan 5, 2026 · A Section 351 transfer occurs when one or more persons transfer property to a corporation in exchange for stock, and immediately after the transfer the transferors control the corporation.
Sec. 351. Transfer To Corporation Controlled By Transferor
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 …
26 USC 351: Transfer to corporation controlled by transferor
A transfer of property of a debtor pursuant to a plan while the debtor is under the jurisdiction of a court in a title 11 or similar case (within the meaning of section 368 (a) (3) (A)), to the extent that the stock …
What is a 351 Transfer? - Asset Strategy
Sep 19, 2024 · A Section 351 transfer is a provision in the U.S. tax code that allows individuals or entities to transfer property to a corporation without recognizing gain or loss at the time of transfer, as …
The IRS’s Gift That Nobody Talks About: A Deep Dive into Section 351 ...
Apr 29, 2026 · Section 351 lets them contribute that IP (patents, trademarks, software, trade secrets) to a new or existing corporation in exchange for stock without triggering gain.