Article Title

Tax-Free Incorporation


For several years, relatively little change had been made in the rules governing the tax-free exchange of property to a corporation. The questions raised in the 1970s about how to handle basis allocation between stock and debt securities had been answered. The problems of distinguishing debt and equity securities had not been resolved but that issue seemed to be less of a burning concern with IRS than it was until the proposed regulations issued in 1980 were revoked in 1983 before becoming final.