Gain or loss according to 1032 and the basis of

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gain or loss according to §1032 and the basis of property received is the basis of the property in hands of the transferor + gain recog. by transferor with the character and holding period tacked. III. REDEMPTION 1. It means that corp. acquires its stock from shareholder in exchange for property (property could be money, securities and any other properties but no stock. §317(a)). 2. Family lineal constructive ownership rules is two steps down, and one step up (meaning from spouse (not incl. separate) down to grandchildren, and from grandchildren to parents.) 3. Beneficiary Attribution a. An entity can beneficiate attribution to their owner from a partnership and/or estates and trust to the extend of their ownership into the partnership and/or trust. Also, an entity can beneficiate attribution to their owner from a corp. only to those shareholders who own 50% or more in the corp.’s stock. But
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stock attributed from a beneficiary to an entity cannot be reattributed out to another beneficiary. b. When it is a beneficiary (a person) to an entity attribution, stock owned by partners, and shareholders is attributed to partnership, estate and/or trust. When it is attributable to a corp., only partners owning 50% or more of the corp. stock is attributed to the corp.
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