Taxation of exchange (SWAP) fund capital gains


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"H.R. 11920 provides that gain realized on a transfer of appreciated stock (or other property) to certain investment companies, in exchange for an interest in a fund, is to be taxable at the time of the exchange. In these cases, the investment company (popularly known as an exchange fund or swap fund) is operated in the form of a partnership in which the various transferors achieve a diversification of their stock or property interests as a result of all exchanges with the fund. The bill also covers two other swap-fund-type transfers: first, it would make mergers of two Investment companies taxable; and, second, it would cover certain reorganizations, such as where mutual funds issue their shares to acquire all of the stock or assets of family-held personal holding companies. The provisions of the bill apply to transfers made after February 17, 1976, in taxable years ending after that date"--Page 1.




Regulated Investment Companies


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Investment Company Act Release


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Partnership Tax Reporter


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Tax Reform (invited Panelists)


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