Transfers to Controlled Corporations:.
In General and Transfers to Controlled Corporations: Related
Problems are both part of Tax Management Inc.'s (Washington, D.C.)
Tax Management U.S. Income Series." In General (#758) discusses the
tax considerations of transferring property to corporations controlled
by the transferors. It analyzes the tax effects of: a transferor's
receipt of property in addition to the stock of the transferee; the
transferor's provision of services in return for such stock; the
transferee ' s assumption of the transferor's liabilities;
and, the determination of the basis and holding period for stock or
property received by either party. Related Problems (#759) discusses the
relationship between Sec. 351 and other provisions of the Code.
Editorial: compares various methods of transferring property to a
controlled corporation; describes the effects and problems arising from
the incorporation of a sole proprietorship, partnership or LLC; shows
the problems related to a Sec. 351 transaction involving foreign
transferees, investment companies and bank holding companies; and, looks
at the recordkeeping, filing, and ruling request requirements of a Sec.
351 transaction. Each of the two volumes costs $125.