Sec. 1.361-1 Nonrecognition of gain or loss to corporations.
Section
361provides the general rule that no gain or loss shall be recognized if a corporation, a party to a reorganization, exchanges property in pursuance of the plan of reorganization solely for stock or securities in another corporation, a party to the reorganization. This provision includes only stock and securities received in connection with a reorganization defined in section
368(a). It also includes nonvoting stock and securities in a corporation, a party to a reorganization, received in a transaction to which section
368(a)(1)(C)is applicable only by reason of section
368(a)(2)(B).
[Adopted by T.D. 6152, 20 FR 8875, Dec. 3, 1955; republished by T.D. 6500, 25 FR 11607, Nov. 26, 1960]