We often have to focus on the details in tax law, and the rules surrounding corporate formation are no exception to this rule. We know that corporations are generally seen as a separate taxable entity from its shareholders. As a result, corporate formations, which involve transfers of property between the shareholders and the corporation, would generally be taxable to both the corporation and the shareholders. This would often discourage corporate formation. Congress remedied this particular problem by enacting Section 351. Did Congress craft a provision that allows corporations and their shareholders to avoid taxation on these transactions permanently, or did it have something else in mind?