How are a transferor’s holding period determined for stock and other property (boot) received in a Sec. 351 exchange?
A. The transferor’s (shareholder’s) holding period for the stock includes the holding period of any non-capital assets (e.g., inventory), capital assets or Sec. 1231 assets transferred.
B. The transferor’s (shareholder’s) holding period for the stock issued in exchange for any capital assets or Sec. 1231 assets transferred begins the day after the exchange date. If the shareholder transfers any other property, the holding period for any stock received includes the holding period of those non-capital assets transferred.
C. The transferor’s (shareholder’s) holding period for the stock includes the holding period of any capital assets or Sec. 1231 assets transferred. If the shareholder transfers any other property, the holding period for any stock received begins on the day after the exchange date.
D. The transferor’s (shareholder’s) holding period for the stock received in exchange for non-capital assets (e.g., inventory), capital assets or Sec. 1231 assets will begin on the day after the exchange date.