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Posted by Stuart A. Bronstein on November 17, 2006, 11:30 pm
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> If I transfer publically held shares of stock from an
> investment account held currently in a personal account with
> Ameritrade into an account titled in an LLC (Partnership)
> with Ameritrade and I receive the proper amount of
> membership interest in the LLC for the amount of current
> market stock value I transfer in, will this be considered a
> non-taxable event? If so, is this a Section 351 or 354
> transfer? Is there anything special I need to do when I
> file my taxes to indicate this or just remember the section
> number I am under?
Unless it's a merger between the corporation and the LLC,
sectino 354 won't apply.
For section 351 to apply the transaction will have to be
done at the same time as other transactions such that those
engaging in those transactions own a total of 80% or mroe of
the equity in the LLC.
There are other issues involved as well, and someone else
who knows those better will come along soon.
Stu
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