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" ... capital stock in payment for organizational and promotional services rendered by E for the benefit of the corporation. E transferred no property to the corporation. C and D were under no obligation to pay for E's services. No gain or loss is recognized... "
The Study of Small Business: The impact of taxation on small business, a ... - 75. lappuse
autors: United States. Small Business Administration. Office of Advocacy - 1977
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The Code of Federal Regulations of the United States of America

1988 - 540 lapas
...to pay for E's services. No gain or loss is recognized to C or D. E received compensation taxable as ordinary income to the extent of the fair market value of the 10 shares of stock received by him. (c) (l) The general rule of section 351 does not apply, and consequently...
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The Code of Federal Regulations of the United States of America

1989 - 568 lapas
...to pay for E's services. No gain or loss is recognized to C or D. E received compensation taxable as ordinary income to the extent of the fair market value of the 10 shares of stock received by him. (c) (1) The general rule of section 351 does not apply, and consequently...
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Internal Revenue Bulletin: Cumulative bulletin

United States. Internal Revenue Service - 1968 - 1034 lapas
...value is income under section 61 of the Code. Accordingly, in the instant case the taxpayer realized ordinary income, to the extent of the fair market value of the installment bonus obligation, in the year in which the lease was executed. However, if the installment...
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The Code of Federal Regulations of the United States of America

1968 - 268 lapas
...to pay for E's services. No gain or loss is recognized to C or D. E received compensation taxable as ordinary income to the extent of the fair market value of the 10 shares of stock received by him. (c) (1) The general rule of section 351 does not apply, and consequently...
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Changes in Bankruptcy Tax Law: Hearing Before the Committee on Ways and ...

United States. Congress. House. Committee on Ways and Means - 1978 - 190 lapas
...taxable as ordinary income if received by the creditor apart from the reorganization, would be treated as ordinary income to the extent of the fair market value of the item. Hearings, p. 2025 (1976). These questions are raised : (1) should there be non-recognition with...
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The Bankruptcy Tax Act and Minor Tax Bills: Hearing Before the Subcommittee ...

United States. Congress. House. Committee on Ways and Means. Subcommittee on Select Revenue Measures - 1979 - 268 lapas
..."security", receives stock in a Section 351 exchange there should be some mechanism to insure that he has ordinary income to the extent of the fair market value of the stock, received. Proposed Section 351 (d) (2) would ensure that gain to that extent is recognized on...
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Regulation, 2007 (Lambers Cpa Exam Review) (Paperback)

Joseph R. Lanciano, Michael F. Farrell, Paul DeBole - 746 lapas
...CORPORATION'S STOCK When a shareholder performs services in exchange for stock, the shareholder must recognize ordinary income to the extent of the fair market value of the stock received. The shareholder's basis in the corporation will be equal to the amount of income recognized....
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Income Tax Regulations, As of January 2008

CCH Tax Law Editors - 2008 - 2242 lapas
...to pay for E's services. No gain or loss is recognized to C or D. E received compensation taxable as ordinary income to the extent of the fair market value of the 10 shares of stock received by him. (c)(l) The general rule of section 351 does not apply, and consequently...
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Federal Tax Study Manual (2008)

Edward C. Foth - 2007 - 426 lapas
...preferred stock for his services in connection with the organization of Networks Corporation. Al has ordinary income to the extent of the fair market value of the stock received. Multiple Choice Indicate the best answer for each of the following items. A, B, C,...
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The Code of Federal Regulations of the United States of America

1966 - 272 lapas
...to pay for E's services. No gain or loss is recognized to C or D. E received compensation taxable as ordinary income to the extent of the fair market value of the 10 shares of stock received by him. § 1.351-2 Receipt of property. (a) If an exchange would be within...
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