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Why Would a Transferor Want to Avoid the Nonrecognition of Gain

question 43

Essay

Why would a transferor want to avoid the nonrecognition of gain under Sec. 351? How can the nonrecognition provision of Sec. 351 be avoided?


Definitions:

Current Price

The present value or selling price of an asset, security, or commodity available in the marketplace.

Put Option

A financial contract that gives the holder the right, but not the obligation, to sell a specified amount of an underlying asset at a set price within a specified time.

Strike Price

The predetermined price at which the buyer of a call option can purchase the underlying asset, or the buyer of a put option can sell the underlying asset.

Pre-Tax Net Profit

The amount of revenue left after deducting all operational, interest, and depreciation expenses, but before paying income taxes.

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