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Tax Lawyer, Vol. 62, No. 1 DETERMINING THE CHARACTER OF SECTION 357(c) GAIN 117Determining the Character of Section 357(c) GainFRED B. BROWN*I. IntroductionUnder section 351, a person transferring property to a controlled corporattio generally recognizes no gain or loss on the transaction;1 thus, such transfers are generally free of federal income tax. An exception to tax-free treatment is contained in section 357(c), which generally provides that a transferor in a section 351 transaction...