Tax Treatment for Exchanges Under ConRail: Hearing Before the Committee on Ways and Means, House of Representatives, Ninety-fourth Congress, Second Session, on H.R. 12490 ... March 12, 1976

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U.S. Government Printing Office, 1976 - Broj stranica: 32
 

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Stranica 3 - No gain or loss shall be recognized if stock or securities in a corporation a party to a reorganization are, in pursuance of the plan of reorganization, exchanged solely for stock or securities in such corporation or in another corporation a party to the reorganization.
Stranica 2 - ... the gain, If any, to the recipient shall be recognized, but In an amount not In excess of the sum of such money and the fair market value of such other property.
Stranica 2 - ... (relating to assumption of liabilities for taxavoidance purposes) the entire amount of the liabilities is treated as money received and (2) for an exchange to which section 371 (relating to reorganizations in certain receivership and bankruptcy proceedings) or section 374 (relating to gain or loss not recognized in certain railroad reorganizations) is applicable, (b) The application of paragraph (a) of this section may be illustrated by the following examples: Example (1).
Stranica 26 - Report of the Commission on the Bankruptcy Laws of the United States...
Stranica 25 - Is a member of an affiliated group of corporations making a consolidated return for such taxable year...
Stranica 3 - To the extent provided in regulations prescribed by the Secretary or his delegate, such term also...
Stranica 3 - ... basis rules of § 1.358-2 to an exchange to which section 354(d) (or so must of section 356 as related to section 354(d)) or 374(c) applies, each certificate of value of the United States Railway Association and the amount of stock of the Consolidated Rail Corporation which related to each certificate shall, so long as they are held by the same person, be treated as one unit of property. (b) Transfer of certificates, stock, or both. If a certificate of value and the amount of stock related to...
Stranica 3 - rail properties" means rail properties within the meaning of paragraph (12) of section 102 of the Regional Rail Reorganization Act of 1973. (B) Transferor railroad corporation. — The term "transferor railroad corporation...
Stranica 3 - Act, (B) any portion of such amount is ineludible in the gross income of such corporation for the taxable year in which such portion is received or accrued, and such taxable year begins not more than 5 years after the date of such award, settlement, or redemption, and (C) the net operating loss of such corporation for any taxable year — (i) was a net operating loss carryover to, or arose in, the first taxable year of such corporation ending after March 31, 1976 (or, in the case of a proceeding...
Stranica 4 - Operators § 1150.11 Introduction. A certificate of designated operator will be issued to an operator providing service pursuant to a rail service continuation agreement under section 304 of the Regional Rail Reorganization Act of 1973, as amended by the Railroad Revitalization and Regulatory Reform Act of 1976. The designated operator (D-OP) may commence and terminate the service in accordance with the terms of the agreement. When service is terminated the D-OP must notify all shippers on the line....

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