The decisions made in issuing corporate stock in a tax-free exchange can have important federal gift tax implications, depending upon how the stock is issued. Especially for transfers involving related transferors, the gift tax consequences can be substantial.
Harl, Neil E.
"Hazards of Issuing Stock for Basis,"
Agricultural Law Digest: Vol. 14
, Article 1.
Available at: http://lib.dr.iastate.edu/aglawdigest/vol14/iss4/1