Create a scenario where the transfer of property to a controlled corporation under Section 351 of th

 

  • Create a scenario where the transfer of property to a controlled corporation under Section 351 of the Internal Revenue Code (IRC) results in the taxation to the transferor. Speculate as to the reasons that gain treatment in the current year may be preferred to the deferral of gain. Provide a tax-planning strategy to prevent taxation of similar transfers. 

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