TaxGuided
United States IRC sections

Statute section

IRC section 351

Transfer to corporation controlled by transferor

Country

United States

Section

351

Updated

2026-05-20

Operative text

Section 351 generally provides nonrecognition treatment when one or more persons transfer property to a corporation solely in exchange for stock, and the transferors are in control (at least 80 percent) of the corporation immediately after the exchange. Boot in addition to stock can trigger partial recognition.

Cross-references

26 U.S.C. 35826 U.S.C. 368

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