Code of Federal Regulations: Containing a Codification of Documents of General Applicability and Future Effect as of December 31, 1948, with Ancillaries and IndexDivision of the Federal Register, the National Archives, 1983 |
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1.–5. rezultāts no 100.
27. lappuse
... facts and circumstances surrounding all of the sales . For this purpose , the fact that the sales may occur during a period of one or more years ( such as in the case of a series of sales by persons who together control each of such ...
... facts and circumstances surrounding all of the sales . For this purpose , the fact that the sales may occur during a period of one or more years ( such as in the case of a series of sales by persons who together control each of such ...
16. lappuse
... facts and circum- stances of each case . One of the facts to be considered in making this deter- mination is the constructive stock ownership of such shareholder under section 318 ( a ) . All distributions in pro rata redemptions of a ...
... facts and circum- stances of each case . One of the facts to be considered in making this deter- mination is the constructive stock ownership of such shareholder under section 318 ( a ) . All distributions in pro rata redemptions of a ...
22. lappuse
... facts and circumstances surrounding all of the sales . For this purpose , the fact that the sales may occur during a period of one or more years ( such as in the case of a series of sales by persons who together control each of such ...
... facts and circumstances surrounding all of the sales . For this purpose , the fact that the sales may occur during a period of one or more years ( such as in the case of a series of sales by persons who together control each of such ...
33. lappuse
... facts and circumstances , it is reasonable to anticipate at the time a distribution is made ( or is deemed to have been made ) with respect to such stock that there is little or no likeli hood of such stock actually participat- ing in ...
... facts and circumstances , it is reasonable to anticipate at the time a distribution is made ( or is deemed to have been made ) with respect to such stock that there is little or no likeli hood of such stock actually participat- ing in ...
41. lappuse
... facts are the same as in Example 1 except that A sold his 50 shares of preferred stock for $ 5,100 . Of this amount $ 5,000 will be treated as ordinary income . No loss will be allowed . There will be added back to the basis of the ...
... facts are the same as in Example 1 except that A sold his 50 shares of preferred stock for $ 5,100 . Of this amount $ 5,000 will be treated as ordinary income . No loss will be allowed . There will be added back to the basis of the ...
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acquires the assets acquiring corporation ending adjusted basis amount attributable to taxes calendar capital loss carrybacks carryover from 1971 classes of stock Corporation's taxable date of distribution date of transfer December 31 deduct or defer defer exploration described in section determined distribution or transfer distributor or trans distributor or transferor dividend carryover dividends paid deduction duction earnings and profits election exchange exploration expenditures fair market value feror corporation foreign tax carryovers gain or loss graph inventories investment credit June 30 liquidation loss corporation method of accounting operating loss carryovers operating loss deduction outstanding stock percent poration preacquisition preceding taxable preferred stock prior taxable provided in section pursuant quiring ration regulations reorganization rules ryovers section 382 section 615 shareholder shares subpara subparagraph taxable income taxable year ending taxable years beginning tion trade or business transaction transferor corporation treated unused foreign tax X Corporation
Populāri fragmenti
53. lappuse - ... more than 50 percent in value of the outstanding stock of which is owned by the same person. (2) Control. For purposes of this paragraph, control means the ownership of stock possessing at least 50 percent of the total combined voting power of all classes of stock entitled to vote or at least 50 percent of the total value of shares of all classes of stock of the corporation.
59. lappuse - If It were not for the fact that the property received In exchange consists not only of property permitted by such paragraph to be received without the recognition of gain, but also of other property or money...
13. lappuse - February 28, 1913, or (2) out of its earnings and profits of the taxable year (computed as of the close of the taxable year without diminution by reason of any distributions made during the taxable year), without regard to the amount of the earnings and profits at the time the distribution was made.
10. lappuse - No gain or loss shall be recognized if stock or securities in a corporation a party to a reorganization are, in pursuance of the plan of reorganization, exchanged solely for stock or securities in such corporation or in another corporation a party to the reorganization.
23. lappuse - ... at least 80 percent of the total combined voting power of all classes of stock entitled to vote and the owner of at least 80 percent of the total number of shares of all other classes of stock (except nonvoting stock which is limited and preferred as to dividends...
159. lappuse - ... such corporation has not continued to carry on a trade or business substantially the same as that conducted before...
73. lappuse - Permanent records in substantial form shall be kept by every taxpayer who participates in a tax-free exchange in connection with a corporate reorganization showing the cost or other basis of the transferred property and the amount of stock or securities and other property or money received (including any liabilities assumed...
59. lappuse - ... trade or business was not acquired by the corporation within such period in a transaction in which gain or loss was recognized in whole or in part.
127. lappuse - ... expended in the acquisition of other property similar or related in service or use to the property so converted, or in the acquisition of control of a corporation owning such other property, or in the establishment of a replacement fund. That section also provides that, if any part of the money is not so expended, the gain, if any, shall be recognized to the extent of the money which is not so expended.
11. lappuse - ... party to the reorganization, stock or securities in such corporation or in another corporation a party to the reorganization, without the surrender by such shareholder of stock or securities in such a corporation, no gain to the distributee from the receipt of such stock or securities shall be recognized.