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 .
Section 351 Transactions And Related Issues Chapter 3 Page i ... equal to the difference between the fair market value of the stock received and the adjusted tax basis of the property transferred. Section 351(a) provides an ... repeal non-recognition treatment for securities received by a transferor in the exchange. In 1997, Congress ...
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