What is the rationale underlying the tax deferral treatment available under § 351?
Realized gain or loss is not recognized in a § 351 transaction when a taxpayer's economic status has not changed.This provision reflects the principle that gain should not be recognized when a taxpayer's investment has not substantively changed.When a business is incorporated,the owner's economic status remains the same;only the form of the investment has changed.

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The Answer of What is the rationale underlying the tax deferral treatment available under § 351?
Realized gain or loss is not recognized in a § 351 transaction when a taxpayer's economic status has not changed.This provision reflects the principle that gain should not be recognized when a taxpayer's investment has not substantively changed.When a business is incorporated,the owner's economic status remains the same;only the form of the investment has changed.

What Is the Rationale Underlying the Tax Deferral Treatment Available