 | Philippines - 1981 - 138 էջ
...with others, not exceeding four persons, gains control of said corporation : Provided, That stocks is'•sUed for services shall not be considered as issued in return for property. "(3) Et,clianfje not solely in kind. — "(a) If, in connection with an exchange described in the above... | |
 | United States - 1965 - 1110 էջ
...or persons are in control (as defined in section 368 (c) ) of the corporation. For purposes of tMs section, stock or securities issued for services shall...not be considered as issued in return for property. (b) Receipt of property. If subsection (a) would apply to an exchange but for the fact thuc there is... | |
 | United States. Tax Court - 1967 - 786 էջ
...exchange t-tieh person or persons are In control (as defined In section 368(c)) of the corporation. For purposes of this section, stock or securities Issued for services shall not be considered aa Issued In return for property. PROCEEDINGS DISPOSED OF UPON MEMORANDUM OPINIONS TC Memo. Name 1966-242... | |
 | 1969 - 268 էջ
...exchange such person or persons are In control (as defined In section 368 (c)) of the corporation. For purposes of this section, stock or securities...not be considered as Issued In return for property. (b) Receipt of property, if subsection (a) would apply to an exchange but for the fact that there Is... | |
 | United States. Internal Revenue Service - 1968 - 938 էջ
...the exchange such person or persons are in control (as defined in section 368(c)) of the corporation. For purposes of this section, stock or securities...not be considered as issued in return for property. * ****** (d) APPLICATION OF JUNE 30, 1967, DATE. — For purposes of this section, if. in connection... | |
 | United States. Internal Revenue Service - 1964 - 744 էջ
...the exchange such person or persons are in control (as defined in section 368 (c) of the corporation. For purposes of this section, stock or securities...not be considered as issued in return for property. ( Emphasis added. ) Since the term "know-how" does not appear in section 351 of the Code, its meaning... | |
 | Wisconsin - 1955 - 890 էջ
...exchange such person or persons are in control (as defined in s. 71. 368 (3) ) of the corporation. For purposes of this section, stock or securities...not be considered as issued in return for property. (2) RECEIPP OF PROPERTY. If sub. (1) would apply to an exchange but for the fact that there is received,... | |
 | Wisconsin - 1955 - 850 էջ
...the exchange such person or persons are in control (as denned in s. 71. 368 (3) ) of the corporation. For purposes of this section, stock or securities...not be considered as issued in return for property. (2) RECEIPT OF PROPERTY. If sub. (1) would apply to an exchange but for the fact that there is received,... | |
 | United States. Congress. House. Committee on Ways and Means - 1958 - 1176 էջ
...which would yield capital gain, the second sentence of section 351 (a) specifically now provides that "stock or securities issued for services shall not...considered as issued in return for property." The advisory group proposes that section 306 stock, like compensation for personal services, be removed... | |
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No gain or loss shall be recognized if property is transferred to a corporation by one or more persons solely in exchange for stock or securities in such corporation and immediately after the exchange such person or persons are in control (as defined... 
