- 8 - (c) are set forth in the margin.3 If the distribution does not 3 SEC. 355. DISTRIBUTION OF STOCK AND SECURITIES OF A CONTROLLED CORPORATION. (a) Effect on Distributees.-- (1) General Rule.--If-- (A) a corporation (referred to in this section as the "distributing corporation") (i) distributes to a shareholder, with respect to its stock, * * * * * * * * * * solely stock or securities of a corporation (referred to in this section as "controlled corporation") which it controls immediately before the distribution, (B) the transaction was not used principally as a device for the distribution of the earnings and profits of the distributing corporation or the controlled corporation or both * * * (C) the requirements of subsection (b) (relating to active businesses) are satisfied, and (D) as part of the distribution, the distributing corporation distributes-- (i) all of the stock and securities in the controlled corporation held by it immediately before the distribution, * * * * * * * * * * then no gain or loss shall be recognized to (and no amount shall be includible in the income of) such shareholder or security holder on the receipt of such stock or securities. (continued...)Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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