collapsible corporation
Defined in 2 dictionaries — Case Law, U.S. Code
Definitions from Case Law
From 374 U.S. 65 - Braunstein v. Commissioner · 1963Most cited · 121 citing opinions
a corporation formed or availed of principally for the manufacture, construction, or production of property with a view to (1) the sale or exchange of stock prior to the realization by the corporation of a substantial part of the net income from the property and (2) the realization of gain attributable to such property
United States Code
26 U.S.C. § 341 — for purposes of this section
For purposes of this section, the term “collapsible corporation” means a corporation formed or availed of principally for the manufacture, construction, or production of property, for the purchase of property which (in the hands of the corporation) is property described in paragraph (3), or for the holding of stock in a corporation so formed or availed of, with a view to—
(A) the sale or exchange of stock by its shareholders (whether in liquidation or otherwise), or a distribution to its shareholders, before the realization by the corporation manufacturing, constructing, producing, or purchasing the property of 2/3 of the taxable income to be derived from such property, and
(B) the realization by such shareholders of gain attributable to such property.