§351 Transfer to Controlled Corporation

Property In, Stock Out, No Current Gain Or Loss  •  80% Voting + 80% Each Nonvoting Class Control Test §368(c)  •  Services Excluded - Stock For Services Is Compensation §83  •  Boot §351(b) Gain To Lesser Of FMV / Realized Gain  •  Liabilities §357(a) / §357(b) / §357(c)  •  Basis §358 / §362 / §362(e)(2)  •  Investment Company §351(e)
IRC §351 / §357 / §358 / §362 / §368(c) / §1223 / Reg §1.351-1 to §1.351-3 Rev. Proc. 77-37 (10% safe harbor); Rev. Rul. 84-111 (partnership to corp) Updated 2026
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IRC §351 (Transfer to corporation controlled by transferor) is the foundational nonrecognition provision for INCORPORATING a business or transferring property to an existing controlled corporation. CORE RULE §351(a): no gain or loss recognized when one or more persons transfer PROPERTY to a corporation SOLELY in exchange for STOCK of that corporation IF, IMMEDIATELY AFTER the exchange, those persons are IN CONTROL of the corporation. CONTROL §368(c): ownership of at least 80% of total combined voting power of all voting-stock classes AND at least 80% of total shares of each nonvoting class. KEY TERMS: "PROPERTY" §351(d) includes cash, real estate, equipment, inventory, intangibles, accounts receivable - but does NOT include services rendered (stock received for services is taxable ordinary compensation income §83). "SOLELY in exchange for stock" - if transferor receives anything besides stock (cash, notes, other property = "BOOT"), §351(b) requires gain (not loss) recognition to the lesser of FMV of boot or realized gain; basis and holding period rules adjust. "IMMEDIATELY AFTER" §1.351-1(a)(1) is judged on a flexible step-transaction basis - includes near-simultaneous transfers part of one integrated plan. CONTROL GROUP - multiple transferors may aggregate property contributions to satisfy 80%/80% test collectively. SERVICE PROVIDER PROBLEM: stock received for services is NOT property contribution; service-only shareholders' shares do NOT count toward 80% control unless they ALSO contribute meaningful property (>10% of stock value contributed as property, per Rev. Proc. 77-37 safe harbor). BASIS §358(a)(1): transferor's basis in stock received = adjusted basis of property transferred, MINUS boot/liabilities, PLUS gain recognized. CORPORATION'S BASIS §362(a): substituted basis = transferor's basis PLUS gain recognized; §362(e)(2) loss duplication rule limits stepped-up basis where aggregate built-in loss transferred. LIABILITIES ASSUMED: §357(a) - generally not boot; §357(b) - tax-avoidance liabilities recharacterized as boot; §357(c) - liabilities EXCEEDING aggregate basis recognized as gain. INVESTMENT COMPANY §351(e) - no nonrecognition where transferee is an investment company (mainly stocks/securities); diversification rule. STATEMENT REQUIRED Reg §1.351-3 - both transferor and corporation attach §351 statement to first return.

§351 in One Paragraph

The trade: Property in, stock out, no current gain or loss - IF the transferors collectively control the corporation immediately after (80% voting + 80% of each nonvoting class per §368(c)).

What counts: Property includes cash, real estate, equipment, intangibles, accounts receivable. Services do NOT - stock for services is ordinary compensation income §83. Service-only shareholders' shares don't help the 80% test.

Boot §351(b): Anything received other than transferee stock (cash, notes, other property). Recognized as gain to the LESSER of boot FMV or realized gain. Losses never recognized.

Liabilities §357: Generally not boot under §357(a). §357(b) tax-avoidance liabilities = boot. §357(c) liabilities ASSUMED in excess of aggregate property basis = gain recognized.

Basis: Transferor takes substituted basis in stock §358(a); corporation takes carryover basis in property §362(a), subject to §362(e)(2) anti-loss-duplication rules. Statement required Reg §1.351-3.

The Three §351 Elements

ElementDetail
(1) PROPERTY transferred§351(a) requires "property"; §351(d) excludes services, indebtedness of transferee corp not evidenced by a security, interest on transferee debt. Property: cash, real estate, equipment, inventory, intangibles (patents, customer lists, goodwill, going concern value), accounts receivable, securities.
Services exclusion §351(d)(1)Stock issued for services rendered = ordinary compensation income to recipient under §83; not property contribution; service shares do NOT count toward 80% control.
(2) SOLELY for STOCK of transfereeStock includes common, preferred (but NOT nonqualified preferred under §351(g)), voting and nonvoting. Excludes: warrants, options, debt instruments, contingent rights.
Nonqualified preferred stock §351(g)Preferred with mandatory redemption, holder put right within 20 years, issuer call where redemption likely, or dividend rate referencing interest rates/commodities - treated as BOOT, not stock
(3) CONTROL immediately after §368(c)Transferors collectively own at least 80% of total combined voting power of all voting-stock classes AND at least 80% of total shares of EACH OTHER class of stock
"Immediately after" timingReg §1.351-1(a)(1) - mutual interdependence test; near-simultaneous transfers part of one integrated plan aggregate; step-transaction doctrine may apply
Multiple transferors§351(a) "one or more persons" - aggregate contributions; control group must hold 80%/80% in aggregate immediately after
Pre-existing corporation§351 works for new and existing corporations; control measured after the transfer regardless of corporation's pre-existing ownership
Stock issuance to new investor concurrentIf new investor receives stock in same plan, transferor group's control percentage may drop below 80% - destroys §351 if not careful
Loss not recognized either§351 is nonrecognition - both gain AND loss deferred; basis preserves loss for later recognition on disposition

The 80%/80% Control Test §368(c)

Control Test ElementDetail
Voting stock testTransferors must own 80% of total combined voting power of all classes of stock entitled to vote
Nonvoting stock testTransferors must own 80% of total number of shares of EACH OTHER class (not aggregated across classes)
"Vertical" test per classEach nonvoting class tested separately; failing 80% on any single nonvoting class breaks control
Attribution§368(c) does NOT apply §318 attribution; each transferor counted individually; family/entity ownership generally not attributed
Treasury stockNot outstanding for purposes of 80% test; only outstanding shares count
Group transferorsMultiple transferors aggregated only if all are "persons" who transferred property and received stock in same transaction
Failure consequencesIf control fails, ENTIRE transfer is taxable; not partial - all gain recognized at FMV minus basis
Concurrent third-party issuanceStock issued to third-party investor in same plan dilutes transferor control; can destroy 80% test
Service-only shareholdersStock for services not property; service-only shares don't count toward transferor group's 80%; Rev. Proc. 77-37 safe harbor: service shareholder must contribute property >10% of FMV of stock received
"Accommodation" property transferSmall property transfer by service provider purely to qualify - IRS may disregard if not "more than nominal"

Boot §351(b)

Boot ElementDetail
DefinitionAnything received in exchange other than stock of transferee corporation - cash, notes, debt instruments, other property
Gain recognition§351(b) - gain recognized to the LESSER of (i) FMV of boot received OR (ii) realized gain on the exchange
Loss never recognized§351(b)(2) - loss never recognized even when boot received; loss carries forward in basis
Character of gainSame as character of property transferred - capital, ordinary, §1245, §1250 recapture; allocation pro rata
Allocation rulesIf multiple assets transferred with mixed character, boot allocated proportionally based on FMV; gain computed per asset
Nonqualified preferred stock §351(g)Specified preferred features = treated as boot, not stock
Securities and debt instrumentsSecurities of transferee corp received in exchange = boot per §351(a) "solely for stock"; pre-2001 rule allowed securities as nonrecognition
Basis adjustment §358(a)(1)Stock basis = property basis MINUS FMV of boot received PLUS gain recognized
Boot received takes FMV basisBoot received takes its own basis = FMV at distribution
Holding periodStock receives tacked holding period from property if capital asset / §1231; boot received starts new holding period

Worked Example - §351 Formation

Worked Example - Multi-Founder Incorporation

Facts: Anna and Frank form Newco, Inc. in 2026. Anna contributes:

- Manufacturing equipment: basis $50,000, FMV $200,000
- Cash: $50,000
Frank contributes:
- Patent portfolio: basis $10,000, FMV $250,000
In exchange, each receives 500 shares of Newco common stock (1,000 total outstanding). Sarah (CTO) also receives 100 shares of restricted stock for services rendered.

§351 control analysis:

Sarah's 100 shares for services - NOT property contribution; do NOT count toward control group
Newco total outstanding: 1,100 shares
Anna + Frank own: 1,000 / 1,100 = 90.9%
90.9% > 80% threshold → §351 CONTROL satisfied → nonrecognition for Anna and Frank

Anna's transfer:

Property transferred: $50K equipment + $50K cash = $100,000 total basis
FMV of property: $200K + $50K = $250,000
Stock received: 500 shares Newco
No boot received → no gain recognition
Anna's basis in 500 shares: $100,000 (substituted basis §358(a)(1))
Newco's basis in equipment: $50,000 (carryover §362(a)); in cash: $50,000
Anna's holding period in stock: tacked from equipment (capital asset)

Frank's transfer:

Property: patent basis $10,000, FMV $250,000 (built-in gain $240,000)
Stock received: 500 shares Newco
No boot → no gain recognition
Frank's basis in 500 shares: $10,000
Newco's basis in patent: $10,000 (carryover)
Built-in gain $240K preserved at corporate level

Sarah's stock for services:

NOT a §351 transfer; treated under §83
Sarah recognizes ordinary compensation income on 100 shares at FMV
If FMV per share = $500 (matching Anna/Frank stock value), Sarah includes $50,000 ordinary income
Sarah should file §83(b) election within 30 days if shares subject to vesting
Newco gets §83(h) deduction matching Sarah's income inclusion

What if Frank also received $50,000 cash boot:

Frank's realized gain: $250K FMV minus $10K basis = $240,000
Boot received: $50,000
§351(b) gain recognized: LESSER of $50,000 boot OR $240,000 realized = $50,000 recognized
Frank's basis in 500 shares: $10,000 - $50,000 + $50,000 = $10,000
$240,000 - $50,000 = $190,000 built-in gain preserved in stock
Character: patent is §1221 capital asset → $50,000 long-term capital gain (if 1-year holding)

Newco basis in patent (with boot):

§362(a) - carryover basis $10,000 PLUS gain recognized by transferor $50,000 = $60,000

Liabilities Assumed §357

§357 ElementDetail
General rule §357(a)Corporation's assumption of transferor's liabilities NOT treated as boot - despite providing equivalent value to transferor
Tax-avoidance liabilities §357(b)If principal purpose of liability assumption was tax avoidance OR not bona fide business purpose, ALL assumed liabilities treated as boot - large potential trap
Liabilities exceeding basis §357(c)If aggregate liabilities assumed EXCEEDS aggregate adjusted basis of property transferred, the EXCESS is GAIN RECOGNIZED (capital or ordinary per character of underlying assets)
§357(c)(1) gain recognitionCannot be deferred; cash-method service businesses with high receivables (no basis) often trip this when incorporating
Exception §357(c)(3) - deductible liabilitiesLiabilities that would give rise to deduction when paid (e.g., accounts payable for cash-basis taxpayer) excluded from §357(c) computation
Aggregation across transferors§357(c) computed PER TRANSFEROR, not aggregated across transferor group
Recourse vs nonrecourseGenerally treated equivalently for §357; substance over form
Strategy: contribute additional basisTransferor can contribute cash or higher-basis property to bring aggregate basis above liabilities and avoid §357(c) gain
Basis effect §358(d)Liabilities assumed reduce transferor's stock basis dollar-for-dollar
Conversion of partnership to corpCommon §357(c) trap - cash-basis partnership with receivables (zero basis) plus payables; structure carefully to avoid gain recognition

Basis and Holding Period

Basis ElementDetail
Transferor's stock basis §358(a)(1)Substituted basis = adjusted basis of property MINUS FMV of boot/liabilities assumed PLUS gain recognized to transferor
Transferor's boot basis §358(a)(2)FMV at distribution date
Corporation's property basis §362(a)Carryover basis = transferor's basis PLUS gain recognized by transferor
§362(e)(2) anti-loss-duplicationWhere aggregate built-in losses > aggregate built-in gains, corporation's basis in built-in-loss property reduced to FMV (stepped DOWN) - or transferor can elect to step DOWN stock basis instead under §362(e)(2)(C)
Loss duplication purposePrevents duplicating loss at both transferor and corporation levels; one loss only
§362(e)(2)(C) basis-shift electionTransferor and corporation jointly elect to reduce stock basis (preserving full asset basis at corp level); election irrevocable
Holding period §1223(1)Transferor's stock holding period = tacked from property holding period IF property is capital asset or §1231 property; otherwise starts new
Corporation's holding period §1223(2)Tacked from transferor
Multiple-asset transferIf both capital and ordinary property contributed, stock receives blended/split holding period based on FMV allocation
Statement Reg §1.351-3Both transferor and corporation attach §351 statement to first return: description of property, FMV, basis, stock received, etc.

Common Practitioner Errors

Service Provider Breaks Control

Stock issued for services is not a property contribution and does NOT count toward 80% test. Practitioner who lets a service founder receive equity at formation without proper property contribution can break §351 control and turn the entire deal taxable. Rev. Proc. 77-37 safe harbor: service shareholder should also contribute property >10% of FMV of stock received.

Concurrent Outside Investor Dilution

Stock issued to a new outside investor in the same plan dilutes the transferor group's control. Practitioner forming a corporation and simultaneously raising equity from a VC must carefully time and structure - if VC takes >20% at formation, §351 control fails.

Forgetting §357(c) Liabilities-Over-Basis

Liabilities assumed in excess of aggregate property basis = gain recognized §357(c). Common trap on cash-basis service business incorporation (high receivables with zero basis + payables). Cure by contributing additional cash/high-basis property.

Accounts Payable §357(c)(3) Exception Missed

§357(c)(3) excludes cash-basis payables (would be deductible when paid) from the §357(c) liabilities-over-basis computation. Practitioner including all payables in the §357(c) test overstates gain recognition.

Investment Company §351(e)

§351 nonrecognition does NOT apply if transferee is an "investment company" - corp with >80% of assets in stocks, securities, money, certain derivatives - PLUS the transaction results in diversification of transferors' interests. Practitioner contributing portfolio assets to a holding corp can inadvertently trigger §351(e).

Nonqualified Preferred Stock as Boot

§351(g) - preferred stock with mandatory redemption, holder put within 20 years, issuer call where redemption likely, or interest-rate-linked dividends is treated as BOOT, not stock. Practitioner issuing preferred without checking §351(g) features can inadvertently trigger gain recognition.

Loss Not Recognized Even With Boot

§351(b)(2) - loss is NEVER recognized in a §351 exchange, even when boot received. Practitioner expecting to recognize loss via partial-boot structure is wrong; loss preserved in stock basis.

§362(e)(2) Loss Duplication Mishandled

If aggregate built-in losses exceed aggregate built-in gains, §362(e)(2) reduces corporation's basis in loss property to FMV - eliminating duplicated loss. Transferor can elect §362(e)(2)(C) to step DOWN stock basis instead, preserving full asset basis. Practitioner ignoring §362(e)(2) misstates basis on both sides.

Step Transaction / Integrated Plan

"Immediately after" judged on integrated-plan basis; near-simultaneous transfers can be aggregated. Practitioner separating transactions in time without genuine business purpose may have steps collapsed - changing control percentage and breaking §351.

Failing to File §351 Statement

Reg §1.351-3 - both transferor and corporation must attach a §351 statement to their first return: property description, FMV, basis, stock received, liabilities assumed, etc. Practitioner omitting the statement creates audit exposure.

Holding Period Misapplication

§1223(1) tacks holding period only for capital and §1231 property. Inventory and other ordinary-character property starts a new holding period on stock received. Practitioner applying tacking to all property miscalculates LTCG on later stock sale.

Pre-Existing Corp Control Failure

§351 works for transfers to existing corps, but transferors must control corp immediately after. Practitioner transferring property to a 60%-owned existing subsidiary may fail control test even with a "controlled" entity.

§357(b) Tax-Avoidance Liability Trap

§357(b) treats ALL assumed liabilities as boot if any liability had tax-avoidance principal purpose. Practitioner allowing transferor to dump tax-motivated liabilities into corporation can blow up entire §351 transfer.

Inventory in §351 Transfer

Inventory is property under §351 but its character flows through for gain recognition and stock holding period. Practitioner not segregating ordinary-character assets misallocates boot gain character.

Going Concern and Goodwill as Property

Self-created goodwill, going concern value, customer lists ARE "property" for §351 purposes if associated with active trade or business. Valuation often disputed; document with appraisal at formation.

Recapture on §1245/§1250 Property

§1245/§1250 recapture potential preserved in transferor stock basis and corporation property basis; recapture eventually recognized on disposition. Practitioner overlooking recapture potential miscalculates long-term tax exposure.

Primary authority: IRC §351 (Transfer to corporation controlled by transferor). §351(a) (general rule - nonrecognition). §351(b) (boot - gain to lesser of boot FMV or realized gain; loss never recognized). §351(c) (special rule for subsidiary stock distributions). §351(d) (items not treated as property - services, indebtedness of transferee, interest). §351(e) (investment company exception). §351(f) (treatment of installment obligations). §351(g) (nonqualified preferred stock as boot). §351(h) (cross references). §357 (assumption of liability). §357(a) (general rule - not boot). §357(b) (tax-avoidance purpose). §357(c) (liabilities in excess of basis - gain recognized). §357(c)(3) (deductible liabilities exception - accounts payable). §358 (basis to distributees). §358(a)(1) (substituted basis to transferor). §358(a)(2) (basis of boot). §358(d) (liabilities reduce stock basis). §362 (basis to corporations). §362(a) (carryover basis in property received). §362(e)(2) (anti-loss-duplication - basis reduction for built-in-loss property). §362(e)(2)(C) (transferor election to reduce stock basis instead). §368(c) (control definition - 80% voting + 80% each nonvoting class). §1223 (holding period). §1223(1) (transferor's stock - tacked if capital or §1231). §1223(2) (corporation's property - tacked). §83 (property transferred in connection with services). §83(h) (employer deduction). §1221 (capital asset). §1245 (depreciation recapture). §1250 (real property recapture). §1366 (S corporation pass-through). §1361 (S corporation election). §1202 (qualified small business stock - original-issue requirement). §7701 (definitions). Reg §1.351-1 through §1.351-3. Reg §1.351-1(a) (transferor and control group). Reg §1.351-1(b) (control test). Reg §1.351-1(c)(1) (investment company). Reg §1.351-3 (statement requirement). Reg §1.358-1, -2, -6 (basis). Reg §1.362-1 (corporation's basis). Reg §1.362-4 (loss duplication). Reg §1.368-1(b) (continuity of interest doctrine analog). Rev. Proc. 77-37 (10% safe harbor for service-shareholder property contribution). Rev. Rul. 68-55 (allocation of boot among multiple assets). Rev. Rul. 83-34 (§351 step-transaction analysis). Rev. Rul. 84-111 (partnership-to-corporation conversion). Commissioner v. Court Holding Co., 324 U.S. 331 (1945) (step transaction). Form 1120 (corporate tax return). Form 7004 (extension).

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