26 U.S. Code § 1032 - Exchange of stock for property
No gain or loss shall be recognized to a corporation on the receipt of money or other property in exchange for stock (including treasury stock) of such corporation. No gain or loss shall be recognized by a corporation with respect to any lapse or acquisition of an option, or with respect to a securities futures contract (as defined in section 1234B), to buy or sell its stock (including treasury stock).
For basis of property acquired by a corporation in certain exchanges for its stock, see section 362.
2000—Subsec. (a). Pub. L. 106–554 inserted “, or with respect to a securities futures contract (as defined in section 1234B),” after “an option” in second sentence.
1984—Subsec. (a). Pub. L. 98–369 inserted provision that no gain or loss shall be recognized by a corporation with respect to any lapse or acquisition of an option to buy or sell its stock (including treasury stock).
Written determinations for this section
These documents, sometimes referred to as "Private Letter Rulings", are taken from the IRS Written Determinations page; the IRS also publishes a fuller explanation of what they are and what they mean. The collection is updated (at our end) daily. It appears that the IRS updates their listing every Friday.
Note that the IRS often titles documents in a very plain-vanilla, duplicative way. Do not assume that identically-titled documents are the same, or that a later document supersedes another with the same title. That is unlikely to be the case.
Release dates appear exactly as we get them from the IRS. Some are clearly wrong, but we have made no attempt to correct them, as we have no way guess correctly in all cases, and do not wish to add to the confusion.
We truncate results at 20000 items. After that, you're on your own.
- Reorganizations Described in Section 368(a)(1)(B) : 2013-06-13
- Stock for Stock (Type "B") : 2013-06-13
- Gain Recognition on Distributions Pursuant to Acquisitions of Greater than 50% of Distributing or Controlled : 2012-12-14
- Reorganizations Described in Section 368(a)(1)(B) : 2012-12-14
- Stock for Stock (Type "B") : 2012-12-14
- Gain Recognition on Distributions Pursuant to Acquisitions of Greater than 50% of Distributing or Controlled : 2012-12-07
- Reorganizations Described in Section 368(a)(1)(B) : 2012-12-07
- Stock for Stock (Type "B") : 2012-12-07
- Deductions For Losses : 2010-06-25
- Capital Expenditures (Deductible v. Not Deductible) : 2010-06-25
- Distributions of Property : 2010-04-09
- Reduction of Tax Attributes : 2007-12-21
- Limitation on Net Operating Loss Carry-forwards and Built-in Losses Following Ownership Changes : 2007-12-21
- Qualified Payment : 2007-12-21
- Unrealized Appreciation of Employer's Securities : 2006-04-14
- Certain Exchanges : 2006-04-14
- Gross Income v. Not Gross Income : 2004-03-12
- Contributions to the Capital of a Corporation : 2004-03-12
- Assets for Control of Transferee (Type "D") : 2004-01-16
- Split-Off : 2004-01-16
- Liability to Which Property is Subject : 2003-08-29
- Nonrecognition of Gain or Loss on Contributions : 2003-08-29
- Transfer to Corporation Controlled by Transferor : 2003-08-29
- In General : 2003-08-29
- Basis to Corporations : 2003-08-29
- Section 704(c) Considerations : 2003-08-29
- Amortization of Goodwill & Certain Other Intangibles : 2003-08-29
- Damages : 2003-08-29
- Capital Asset v. Not a Capital Asset : 2003-08-29
- Basis to Distributees : 2003-08-29
- Shareholder Contributions : 2003-08-29
- Basis of Property Contributed to Partnership : 2003-08-29
- Property Used in : 2003-08-29
- Stockholders Contributions : 2003-08-29
- Assigned : 2003-08-29
- Control v. No Control : 2003-08-29
- Stock of Members : 2002-08-09
- Interest : 2001-10-26
- Limitation on Net Operating Loss Carry-forwards and Built-in Losses Following Ownership Changes : 2001-10-26
- Trade or Business (Deductible v. Not Deductible) : 2001-10-26
- Deduction by Employer : 2000-08-04
- Option to Buy or Sell : 2000-03-17
- Taxability of Corporation on Distribution : 2000-01-28
- Distributions of Appreciated Property : 2000-01-28
- Gross Income v. Not Gross Income : 1999-12-31
- Contributions to the Capital of a Corporation : 1999-12-31
- Definitions : 1999-10-01
- With Respect to its Stock : 1999-08-20
- Allocation of Income and Deductions Among Taxpayers : 1999-08-20
- Persons Treated as Grantors : 1999-06-25
- Deduction for Contributions of Employer to an Employee's Trust or Annuity Plan and Compensation Under a Deferred-Payment Plan (Deduct. v. Not Deduct.) : 1999-06-25
- Statutory Exemptions : 1999-06-25
- Release From Contract : 1999-04-02
- Deferred Compensation : 1999-01-29
- Deduction by Employer : 1999-01-29
- Deferred Compensation : 1999-01-22
- Deduction by Employer : 1999-01-22
- Deferred Compensation : 1999-01-22
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