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Video of How to Determine Holding Period of Stock in a Section 351 Transaction (U.S. Corporate Tax) in Tax Accounting course by Edspira channel, video No. 15 free certified online
This video explains how to determine the holding period for stock received by the transferor in a Section 351 transaction. For capital assets and Section 1231 assets, the holding period of the asset transferred tacks on to the holding period of the stock the transferor is receiving from the corporation. For example, if the transferor transfers a capital asset in exchange for the corporation's stock, and the transferor had held the capital asset for 6 months prior to the Section 351 transaction, then sells the stock received in the Section 351 transaction 8 months after receiving it, the holding period would be 14 months (thus, the gain or loss would be long-term, not short-term). When the transferor transfers ordinary assets in a Section 351 transaction, however, the holding period of the asset does not tack on to the holding period of the stock received (and thus the holding period begins the day after the Section 351 transaction).—
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