The control requirement under § 351 requires that the person or persons transferring property to the corporation immediately after the transfer own stock possessing at least 80% of the total combined voting power of all classes of stock entitled to vote and at least 80% of the total number of shares of all other classes of stock of the corporation.

Question

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Section 351 of the Internal Revenue Code requires that for a transfer of property to a corporation to be tax-free, the transferor(s) must control the corporation immediately after the transaction, with "control" defined as owning at least 80% of both the total combined voting power of all voting stock and at least 80% of the total shares of each other class of nonvoting stock.

The Control Requirement Under § 351 Requires That the Person