Tax Aspects of Incorporations

Tax Aspects of Incorporations

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Description

This chapter discusses the United States federal income tax issues that arise in connection with the formation of a new corporation (Newco). When a Newco is formed, the initial owners may contribute cash, property, or services in exchange for shares of Newco stock. Because there is no built-in gain or loss inherent in cash, the acquisition of stock for cash does not result in any immediate tax consequences. Contributions of property or services, on the other hand, raise far more interesting tax issues. Section I of this chapter examines the tax issues relating to contributions of property, while Section II discusses contributions of services.

Source Publication

Research Handbook on Corporate Taxation

Source Editors/Authors

Reuven S. Avi-Yonah

Publication Date

2023

Tax Aspects of Incorporations

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