The Controller was approached by some business colleagues about doing a Section 351 transaction for the formation of a new separate corporation.  Big Corporation has a nice parcel of land that they bought for $10,000 but it is worth now $1,000,000.  Big Corporation does not want to just sell it because that would be an immediate recognized gain of $990,000 on their tax return.  But the Controller heard that if that land were contributed to the new corporation for stock in the new corporation worth $1,000,000, it would not be taxable.  Can a Section 351 transaction defer the taxable income if that property is contributed?

SWFT Individual Income Taxes
43rd Edition
ISBN:9780357391365
Author:YOUNG
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Chapter4: Gross Income: Concepts And Inclusions
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The Controller was approached by some business colleagues about doing a Section 351 transaction for the formation of a new separate corporation.  Big Corporation has a nice parcel of land that they bought for $10,000 but it is worth now $1,000,000.  Big Corporation does not want to just sell it because that would be an immediate recognized gain of $990,000 on their tax return.  But the Controller heard that if that land were contributed to the new corporation for stock in the new corporation worth $1,000,000, it would not be taxable.  Can a Section 351 transaction defer the taxable income if that property is contributed?

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