26 C.F.R. § 1.356-5 Transactions involving gift or compensation.
Title 26 - Internal Revenue
With respect to transactions described in sections 354, 355, or 356, but which— (a) Result in a gift, see section 2501 and following, and the regulations pertaining thereto, or (b) Have the effect of the payment of compensation, see section 61(a)(1), and the regulations pertaining thereto.
Title 26: Internal Revenue
PART 1—INCOME TAXES
effects on shareholders and security holders
§ 1.356-5 Transactions involving gift or compensation.