Gain Recognition AgreementMarch 12th, 2021
FiledMarch 12th, 2021Certain transfers of appreciated property in the course of a corporate organization, reorganization, or liquidation can be made without recognition of gain to the trans- feror or to the corporation involved. When a transaction involves an “outbound transfer,” (i.e., a transfer from a U.S. person1 to a foreign corporation) Code §367(a)