Sec. 351 transfers as “bargain purchases.”: An article from: The Tax Adviser

Sec. 351 transfers as "bargain purchases.": An article from: The Tax Adviser





This digital document is an article from The Tax Adviser, published by American Institute of CPA's on June 1, 1996. The length of the article is 487 words. The page length shown above is based on a typical 300-word page. The article is delivered in HTML format and is available in your Amazon.com Digital Locker immediately after purchase. You can view it with any web browser.

From the supplier: The IRS is currently considering extending the reasoning it used in Hamilton Industries regarding bargain purchases of inventory to IRC section 351 transfers of low-basis inventory. Under Hamilton, taxpayers that receive inventory at bargain prices cannot treat that inventory and new inventory as the same LIFO items. The separate treatment results in tax on the bargain element. In Letter Ruling 9446003, the IRS suggested that inventory originally purchased at bargain rates and then transferred under section 351 retains its distinctness from new inventory in the transferee's hands.

Citation Details
Title: Sec. 351 transfers as "bargain purchases."
Author: Frank J., Jr. Kalis
Publication: The Tax Adviser (Magazine/Journal)
Date: June 1, 1996
Publisher: American Institute of CPA's
Volume: 27 Issue: n6 Page: 328(1)

Distributed by Thomson Gale









List Price: $ 5.95



Price: $ 5.95









Find More Bargain Products