Make a scenario where the transfer of property to controlled corporation under Section 351 of Internal Revenue Code (IRC) results in the taxation to the transferor. Evaluate the fairness of the taxation of the transaction to the transferor. Provide a tax-planning strategy to prevent taxation of similar transfers.
From the e-Activity, examine the differences in the treatment of nonmonetary transactions in corporate formations under GAAP versus under Section 351 of the IRC. Suggest the main possible reason for these differences.