§ 351

Rev. Rul. 80-228: Anti-Wham
Rev. Rul. 85-164: Basis and holding period in § 351 transfer
Rev. Rul. 83-156: § 351 transfer followed by § 721 contribution
Rev. Rul. 83-34: Successive section 351 transfers
Rev. Rul. 76-123: C reorg in context of § 351
Rev. Rul. 79-194, Sit. 2: Stock sold to 1% transferor; fails § 368(c)
Rev. Rul. 79-194, Sit. 1: Owner shifts among § 351 transferors
Rev. Rul. 58-93: Recast into A with (a)(2)(C) drop
Rev. Rul. 79-70: § 368(c) control is broken by a planned sale of stock
Rev. Rul. 84-44: No § 368(c) control in multi-step transaction
Rev. Rul. 68-349: Failed 351 exchange inconnection with F reorg
Rev. Rul. 70-140: Transitory stock ownership fails § 368(c) control
Rev. Rul. 84-111, Sit. 3: § 351 exchange terminates partnership
Rev. Rul. 84-111, Sit. 2: § 351 exchange follows partnership termination
Rev. Rul. 84-111, Sit. 1: § 351 exchange preceding partnership termination
Rev. Rul. 95-74: Contingent environmental liabilities and § 351
Rev. Rul. 84-71: COI not required in a § 351 despite reorg overlap
Rev. Rul. 80-323: § 357(c) applies to § 351 transfer of a partnership interest
Rev. Rul. 2007-8, Sit. 2: Overlapping § 368(a)(1)(C) with § 351
Rev. Rul. 2007-8, Sit. 1: Overlapping § 368(a)(1)(D)/354 with § 351
Rev. Rul. 2015-9: Section 351 transfer with D reorg and step transaction
Rev. Rul. 2003-51: Successive § 351 exchanges and control requirement
Rev. Rul. 2015-10: Triple drop and check (351 exchanges with D reorg)
Rev. Rul. 2017-9, Sit. 1: North-South Ruling - Transfers treated as separate
Rev. Rul. 77-449: Double-drop transfers governed by § 351
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