...Commissioner of Internal Revenue must give clearance by determining in advance that the transaction "is not in pursuance of a plan having as one of its...principal purposes the avoidance of Federal income taxes." Generally the Commissioner has been unwilling to grant such approval where there is an appreciable...

...not be considered to be a corporation unless it is established to the satisfaction of the Secretary that such exchange is not in pursuance of a plan having...principal purposes the avoidance of Federal income taxes. The determination that such exchange is not in pursuance of such a plan must be made pursuant to a...

...355, 356 or 361, a foreign corporation shall not be considered a corporation unless it is established that such exchange is not in pursuance of a plan having...principal purposes the avoidance of Federal income taxes." Section 367. as it has existed since 1932, apparently would require the securing of advance rulings...

...exchange, it has been established to the satisfaction of the Secretary of the Treasury or his delegate that such exchange is not in pursuance of a plan having...principal purposes the avoidance of Federal income taxes. Section 354 of the Code provides, in general, that no gain or loss shall be recognized if stock or...

...law and must be the basis upon which the instant case is decided. The relevant language thereunder is that "such exchange is not in pursuance of a plan...principal purposes the avoidance of Federal income taxes." Neither Congress in its hearings nor respondent in his rulings has ever defined what is meant by a...

...prescribed by regulations by the Secretary), it is established to the satisfaction of the Secretary that such exchange is not in pursuance of a plan having...principal purposes the avoidance of Federal income taxes. "(2) EXCEPTION FOR TRANSACTIONS DESIGNATED BY THE SECRETARY. — Paragraph (1) shall not apply to any...

...unless at a specified time, it has been established to the satisfaction of the Secretary or his delegate that such exchange is not in pursuance of a plan having...principal purposes the avoidance of Federal income taxes. Unless the exchange described in that section 367 (a) was a mere change of form of a foreign corporation...

...such exchange it has been established to the satisfaction of the Secretary or the Secretary's delegate that such exchange is not in pursuance of a plan having...principal purposes the avoidance of Federal income taxes. Section 1.367-1 of the Income Tax Regulations provides, in part, that such a planned transaction should...

...prescribed by regulations by the Secretary), it is established to the satisfaction of the Secretary that such exchange is not in pursuance of a plan having...principal purposes the avoidance of federal income taxes. The transfer of property (country A francs) by P (a domestic corporation) to S (its wholly owned foreign...

...though it is made subject to a condition that, if there is a failure to obtain a determination that the exchange is not in pursuance of a plan having as one...principal purposes the avoidance of Federal income taxes, the transaction will not be consummated and to the extent possible the assets transferred will be returned....