Section 28 Formation of a Subsidiary
| Library | Bus Trans 2005 |
A corporation can restructure its operation by forming one or more subsidiary corporations under I.R.C. § 351.
The Omnibus Budget Reconciliation Act of 1989, enacted December 19, 1989, Pub. L. No. 101-239, 103 Stat. 2106, amended I.R.C. § 351 to delete the application of that provision to the issuance of securities. The issuance of securities in connection with the transfer of appreciated property to a controlled corporation is currently subject to tax, except to the extent that the installment sale rules...
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