Transcription of SECTION 351 TRANSACTIONS AND RELATED ISSUES
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SECTION 351 TRANSACTIONS AND RELATED ISSUES
SECTION 351 TRANSACTIONS AND RELATED ISSUES by R. DAVID WHEAT, Dallas Thompson & Knight LLP State Bar of Texas 24TH ANNUAL ADVANCED TAX LAW COURSE September 28-29, 2006 Dallas CHAPTER 3 999999 999999 DALLAS Biography R. David Wheat Thompson & Knight LLP 1700 Pacific Avenue, Suite 3300 Dallas, Texas 75201 (214) 969-1468 E-mail: David Wheat is a senior partner in the Dallas office of Thompson & Knight LLP. He has an in Taxation from NYU. He is Past Chair of the ABA Corporate Tax Committee. He is also a former Chair of the Dallas Bar Tax SECTION and the State Bar of Texas Tax SECTION . David Wheat has been voted by his peers as one of the Best Lawyers in Dallas in his field and has been selected one of the Best Lawyers in America.
corporation’s stock are treated as boot, and thus, cannot be received tax-free in a Section 351 exchange.16 5. Put Rights - Rev. Rul. 69-265 The IRS in Rev. Rul. 69-265 concluded that certain put rights are boot.17 Situation 1 of Rev. Rul. 69-265 involved a triangular C reorganization where the target shareholders received parent corporation
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