How to beat Rev. Rul. 68-55. (IRC section 351 allocation method): An article from: The Tax Adviser

This digital document is an article from The Tax Adviser, published by American Institute of CPA's on June 1, 1997. The length of the article is 578 words. The page length shown above is based on a typical 300-word page. The article is delivered in HTML format and is available in your Amazon.com Digital Locker immediately after purchase. You can view it with any web browser.

From the supplier: A holding company can be used to avoid the recognition of income under the allocation method required for IRC section 351 asset transfers that involve boot. Under Revenue Ruling 68-55, an asset-by-asset method must be used to allocate gain or loss in proportion to relative asset values. If the purchaser creates a subsidiary and the asset that would trigger gain is transferred to the purchaser and then to the subsidiary, the transfer is tax-free. Subsequent transfer of assets not triggering gain recognition would be treated as separate transactions.

Citation Details
Title: How to beat Rev. Rul. 68-55. (IRC section 351 allocation method)
Author: Richard W. Bailine
Publication:The Tax Adviser (Magazine/Journal)
Date: June 1, 1997
Publisher: American Institute of CPA's
Volume: 28 Issue: n6 Page: 341(2)

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