Extract to table

§ 355(e) Plan Risk IRC § 355(e) provides that if a distribution that otherwise qualifies under Section 355 is "part of a plan (or series of related transactions)" pursuant to which one or more persons acquire, directly or indirectly, stock representing a fifty-percent-or-greater interest (by vote or value) in the distributing corporation or any controlled corporation, the distributing corporation shall recognize gain on the distribution as if the stock of the controlled corporation distributed were sold for its fair market value on the date of distribution