CH. 1—NORMAL TAXES AND SURTAXES
131
of this subsection, be treated as owning (immediately after the reorganization) a percentage of the fair market value of the acquiring corporation's outstanding stock which bears the same ratio to the percentage of the fair market value of the outstanding stock of the loss corporation (immediately before the reorganization) owned by such transferor corporation or acquiring corporation as the fair t' market value of the total outstanding stock of the loss corporation (immediately before the reorganization) bears to the fair market ^i- value of the total outstanding stock of the acquiring corporation (immediately after the reorganization). (6) STOCK OF CORPORATION CONTROLLING ACQUIRING CORPORA-
TION.—If the stockholders of the loss corporation (immediately before the reorganization) own, as a result of the reorganization, stock in a corporation controlling the acquiring corporation, such r stock of the controlling corporation shall, for purposes of this subsection, be treated as stock of the acquiring corporation in an amount valued at an equivalent fair market value. (c) DEFINITION OF STOCK.—For purposes of this section, "stock" means all shares except nonvoting stock which is limited and preferred as to dividends.
Y;
PART VI—EFFECTIVE DATE OF SUBCHAPTER C Sec. Sec. Sec. Sec. Sec.
391. 392. 393. 394. 395.
Effective date of part I. Effective date of part II. Effective dates of parts III and IV. Effective date of part V. Special rules for application of this subchapter.
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SEC. 391. EFFECTIVE DATE OF PART I.
Except as otherwise provided in this subchapter, part I shall take effect on June 22, 1954. Section 306 shall apply only with respect to dispositions (or redemptions) occurring on or after June 22, 1954. SEC. 392. EFFECTIVE DATE OF PART II. (a) GENERAL RULE. — E x c e p t as otherwise provided in this sub-
chapter, part II shall apply with respect to a plan of liquidation only if the first distribution in pursuance of such plan occurs on or after June 22, 1954. Section 341 shall apply only with respect to sales, exchanges, and distributions on or after June 22, 1954. (b) SPECIAL RULE FOR CERTAIN SALES D U R I N G 1954.— (1) NONRECOGNITION OF GAIN OR LOSS.—If—
"•/ I)
(A) all of the assets of a corporation (less assets retained to meet claims) are distributed before January 1, 1955, in complete liquidation of such corporation; and li (B) the corporation elects (at such time and in such manner as the Secretary or his delegate may by regulations prescribe) to a have this subsection apply, then no gain or loss shall be recognized to such corporation from the sale or exchange by it of property during the calendar year 1954. (2) CERTAIN PROVISIONS OF SECTION 337 MADE APPLICABLE.—For
purposes of paragraph (1)— (A) the term "property" has the meaning given to such term by section 337(b); except that any determination required by § 392(b)(2)(A)
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