74TH CONGRESS . SESS. II. CH. 690 . J UNE 22, 1936.
16 79 (3) STOCK FOR STOCK ON REORGANIZATION .-No gain or loss shall be recognized if stock or securities in a corporation a party to a reorg anizat ion ar e, in pursua nce of the p lan of reorg anizat ion, exchanged solely for stock or securities in such corporation or in another corporation a party to the reorganization . (4) SAME-GAIN OF CORPORATION .-No gain or loss shall be recognized if a corporation a party to a reorganization exchanges property, in pursuance of the plan of reorganization, solely for stock or securities in another corporation a party to the reorgani- zat ion . (5) TRANSFER TO CORPORATION CONTROLLED BY TRAN SFEROR .-NO Transfers for stock of corporation under same gain or loss shall be recognized if property is transferred to a control . corporation by one or more persons solely in exchange for stock or securities in such corporation, and immediately after the exchange such person or persons are in control of the corporation ; but in Limitation . the case of an exchange by two or more persons this paragraph shall apply only if the amount of the stock and securities received by each is substantially in proportion to his interest in the property prior to the exchange . (6) PROP ERTY REC EIVE D BY COR PORA TION ON COMP LETE LIQ UIDA TION Property received by co rpor atio n on co m- OF ANOTHER .-No gain or loss shall be recognized upon the receipt plete liquidation of by a corporation of property distributed in complete liquidation another. of anothe r corp oratio n . For the purpos es of this paragraph a distribution shall be considered to be in complete liquidation only if- (A) the corporation receiving such property was, on the date Conditions pre . of the adoption of the plan of liquidation, and has continued to scribed . be at all times until the receipt of the property, the owner of stock (in such other corporation) possessing at least 80 per centum of the total combined voting power of all classes of stock entitled to vote and the owner of at least 80 per centum of the total number of shares of all other classes of stock (except non- votin g stoc k whic h is l imited and p referr ed as to div idends ), and was at no time on or after the date of the adoption of the plan of liq uidati on and until the r eceipt of th e prop erty t he owner of a greater percentage of any class of stock than the per- centage of such class owned at the time of the receipt of the property ; and (B) no distribution under the liquidation was made before the fore os distr ibut ion be- first day of the first taxable year of the corporation beginning after December 31, 1935 ; and either C the distribution is b such other corporation in complete e Distribution can a oom- )
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cancelation, cancellation or redemption of all its stock, and the transfer of e t c l al.l the property occurs within the taxable year ; in such case the adopt ion by the s tockho lders of the resol ution under which is authorized the distribution of all the assets of such corporation in complete cancellation or redemption of all its stock, shall be considered an adoption of a plan of liquidation, even though no time for the completion of the transfer of the property is speci- fied in such resolution ; or (D) such distribution is one of a series of distributions by Distribution one of series of distributions, such other corporation in complete cancellation or redemption of etc .
- period for corn-
all it s stock in accor dance wi th a pla n of liq uidatio n under which p1etton . the transfer of all the property under the liquidation is to be completed within three years from the close of the taxable year during which is made the first of the series of distributions under the plan, except that if such transfer is not completed within such period, or if the taxpayer does not continue qualified under subparagraph (A) until the completion of such transfer, no Stock for stock on re- organization, Prope rty for stoc k of party to reorganization .
