Law College

A §351 deferral is only available when a single shareholder transfers property for a controlling stock interest in a corporation. true or false?

Answers

Answer 1

False. A Section 351 deferral under the Internal Revenue Code is available when a shareholder transfers property to a corporation in exchange for stock, and it can apply to both single and multiple shareholders.

Under Section 351, the transfer of property to a corporation is not taxable if the transfer is made in exchange for stock in the corporation, and if immediately after the transfer, the transferor and other persons who transfer property to the corporation (if any) own at least 80% of the total combined voting power of all classes of stock entitled to vote and at least 80% of the total number of shares of all other classes of stock of the corporation.

Therefore, it is not necessary for a single shareholder to transfer property for a controlling stock interest in a corporation to qualify for a Section 351 deferral. Multiple shareholders can transfer property to the corporation and still qualify for the deferral if the 80% ownership requirement is met.

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Answer 2

It is true that a §351 deferral is only available when a single shareholder transfers property for a controlling stock interest in a corporation.

A §351 deferral is available when one or more shareholders transfer property to a corporation in exchange for stock, and the transferors are in control of the corporation immediately after the exchange. The control requirement is met if the transferors own at least 80% of the total combined voting power and 80% of the total number of shares of all other classes of stock. It is not limited to a single shareholder.

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Related Questions

some believe this rule is upheld by the wealthy to oppress the poor, a view that aligns with the ______ perspective.

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some believe this rule is upheld by the wealthy to oppress the poor, a view that aligns with the Marxist perspective.

The Marxist perspective is based on the works of Karl Marx, who believed that the wealthy exploit the working class in order to maintain their power and wealth. The idea of the wealthy upholding a rule to oppress the poor is an example of this exploitation.

The wealthy are able to manipulate the rules and laws in their favor, while the poor are left behind with no voice or power. This creates an unequal society, where the working class is unable to achieve economic prosperity. The wealthy use their power to maintain their privileged status, while the poor are left to suffer in poverty.

This view aligns with the Marxist perspective, as it highlights the unequal power distribution between the wealthy and the working class in society. Ultimately, this rule is seen as a means to maintain the status quo and further the interests of the wealthy at the expense of the poor.

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policies and practices intended to focus on health promotion and disease prevention should

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Policies and practices intended to focus on health promotion and disease prevention should prioritize several important factors. Here are some general considerations:

1. Focus on evidence-based interventions: Policies and practices should be based on the best available scientific evidence. This means identifying and implementing interventions that have been shown to be effective in promoting health and preventing disease.

2. Address social determinants of health: Policies and practices should take into account the social and economic factors that influence health outcomes. This includes addressing issues such as poverty, access to healthy food, safe housing, and quality education.

3. Be inclusive and equitable: Policies and practices should be designed to meet the needs of diverse populations, including those who are traditionally underserved or marginalized. This means considering issues such as cultural competence, language access, and health literacy.

4. Foster collaboration: Health promotion and disease prevention policies and practices should be developed in collaboration with stakeholders from different sectors, including healthcare, public health, education, and community organizations.

5. Embrace a systems approach: Policies and practices should recognize that health promotion and disease prevention are complex issues that require a systems approach. This means addressing multiple factors across multiple levels, including individual behaviors, social and environmental factors, and policies and systems.

Overall, policies and practices intended to focus on health promotion and disease prevention should be comprehensive, evidence-based, and designed to address the social, economic, and environmental factors that influence health outcomes.
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