Home      Login


The Investment Company Exception to Sections 351 and 721 Needs Clarification, But Legislative Proposals May Add to the Confusion by Expanding the Reach of the Investment Company Rules  


Author:  Stanley E. Ramsay.


Source: Volume 20, Number 01, Fall 2002 , pp.3-13(11)




Journal of Taxation of Investments

next article > |return to table of contents

Abstract: 

Section 351(a), which generally provides for nonrecognition of gain or loss on the transfer of property to a corporation which is controlled by the transferors immediately after the transfer, does not apply to the transfer of property to an investment company.1 As a result, a transferor recognizes gain or loss in connection with the contribution of property to an investment company.

Keywords: 

Affiliations:  1: Weil, Gotshal & Manges LLP.

Subscribers click here to open full text in PDF.
Non-subscribers click here to purchase this article. $20

next article > |return to table of contents