what is a 351 transaction
The transferee. corporation's basis in the property transferred by the transferor in a. Section 351 transaction generally is the same as the transferor's basis, increased by the amount of any gain recognized by the transferor.roup, and the group will own control of Holdco after the transaction. Accordingly, Section 351 will apply to each of A, B, E and F (as to A. and B, the transaction also may qualify as a reorganization under. Section 368(a)(1)(B)).
B. Sec. 351 Transfers Basis of Property Received by Corporation. 1. The corporation s basis in the property received is determined as follows: 2. Figure 1 presents a variety of transactions involving Sec. 351 transfers.Gain computations and basis computations are included. Review these examples carefully.he corporation s basis in the property received is determined as follows: 2. Figure 1 presents a variety of transactions involving Sec. 351 transfers. Gain computations and basis computations are included.