The Definition of Property as It Relates to a Section
The definition of property as it relates to a section 351 transaction includes money.
To meet the control test under section 351, a taxpayer transferring property to a corporation must by himself own 80 percent or more of the corporation's voting stock and 80 percent of each class of nonvoting stock after the transfer even if there are other transferors of property.
Gain or loss realized in a section 351 transaction will be recognized if the taxpayer receives boot in the exchange.
A taxpayer must receive voting common stock to be eligible for deferral in a section 351 exchange.