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When improperly planned, a Sec 351 transaction can lose its tax-absolutely free position and become subjected for the tax treatment of liabilities wherever acquire is regarded as established forth in Sec 357. A number of procedures could be utilized to stay away from the adverse consequences of Sec 357. As an illustration, in scenarios exactly where pre-incorporation liabilities surpass the basis of belongings to become exchanged, the quantity of basis might be elevated by like supplemental home inside the transfer or by settling the deficiency in cash or A different unburdened asset.
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eleven(b). Through the reporting time period did the labor organization Have got a subsidiary Group as outlined in Section X of such Guidelines?
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