No coin nor oath required. For personal study only.
Bruce R. Hopkins
he IRS has proposed regulations concern-T ing the liquidation of for-profit entities into tax-exempt organizations (REG-209 12 1- 89). The general rule under this proposal is that the taxable corporation must recognize gain or loss in the transaction. These regulations will also apply where a for-profit corporation converts to a tax-exempt entity.
The proposed regulations provide that, in general, a taxable corporation that transfers all or substantially all of its assets to one or more tax-exempt organizations is required to recognize gain or loss as if the assets transferred were sold at their fair market value. This gain or loss is to be recognized immediately before the transfer.
π SIMILAR VOLUMES
The Internal Revenue Service issued new proposed regulations on incentive stock options (ISOs), replacing previous regulations issued in 1984. These new proposed regulations retain some of the rules from the earlier regulations and expand on them, while also making changes in a few areas. Although t