Section 351 Disclosure Statement

351 exchange to his or her tax return including a description of why it is a good business purpose.

Section 351 disclosure statement. The transferor s and transferee s must attach the written documentation in creating the sec. On 6 15 06 the taxpayer transferred the property listed below to. Transferors code section 351 disclosure statement name.

A version of section 351 has been included in the internal revenue code since the revenue act of 1921 2 in 1989 congress amended section 351 to repeal non recognition treatment for securities received by a transferor in the exchange. S corp of junk tin. Section 351 a is intended to apply to certain transactions where gain or loss may have accrued in a constitutional sense but where in a popular and economic sense there has been a mere change in the form of ownership and the taxpayer has not really cashed in on the theoretical gain or closed out a losing venture.

If the requirements of section 355 or so much of section 356 as relates to section 355 are met with respect to a distribution described in paragraph 1 then solely for purposes of determining the tax treatment of the transfers of property to the controlled corporation by the distributing corporation the fact that the shareholders of the distributing corporation dispose of part or all of. 1 351 3 records to be kept and information to be filed. 1442 a walnut st 365.

2006 taxpayer submits the following statement pursuant to the requirements of reg 1 351 3 a.