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)
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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.