26 CFR 1.361-1
§ 1.361-1 Nonrecognition of gain or loss to corporations.
United States · 26 CFR — Internal Revenue · Status: effective
Cite this
- Citation
- 26 CFR 1.361-1, § 1.361-1 Nonrecognition of gain or loss to corporations, United States, version 1 as recorded 2026-07-09, yourstate.us, https://yourstate.us/provision/109682
- Permanent ID
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Full text
Section 361 provides the general rule that no gain or loss shall be recognized if a corporation, a party to a reorganization, exchanges property in pursuance of the plan of reorganization solely for stock or securities in another corporation, a party to the reorganization. This provision includes only stock and securities received in connection with a reorganization defined in section 368(a). It also includes nonvoting stock and securities in a corporation, a party to a reorganization, received in a transaction to which section 368(a)(1)(C) is applicable only by reason of section 368(a)(2)(B).
Legislative history
This is a federal regulation, adopted through agency rulemaking under the Administrative Procedure Act — not enacted by a recorded vote of Congress.