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26 USC § 1036 - Stock for stock of same corporation

---
identifier: "/us/usc/t26/s1036"
source: "usc"
legal_status: "official_prima_facie"
title: "26 USC § 1036 - Stock for stock of same corporation"
title_number: 26
title_name: "INTERNAL REVENUE CODE"
section_number: "1036"
section_name: "Stock for stock of same corporation"
chapter_number: 1
chapter_name: "NORMAL TAXES AND SURTAXES"
subchapter_number: "O"
subchapter_name: "Gain or Loss on Disposition of Property"
part_number: "III"
part_name: "COMMON NONTAXABLE EXCHANGES"
positive_law: false
currency: "119-84"
last_updated: "2026-04-17"
format_version: "1.1.0"
generator: "[email protected]"
source_credit: "(Aug. 16, 1954, ch. 736, 68A Stat. 309; Pub. L. 105–34, title X, § 1014(e)(3), Aug. 5, 1997, 111 Stat. 921.)"
---

# § 1036. Stock for stock of same corporation

**(a)** **General rule** No gain or loss shall be recognized if common stock in a corporation is exchanged solely for common stock in the same corporation, or if preferred stock in a corporation is exchanged solely for preferred stock in the same corporation.

**(b)** **Nonqualified preferred stock not treated as stock** For purposes of this section, nonqualified preferred stock (as defined in section 351(g)(2)) shall be treated as property other than stock.

**(c)** **Cross references**

**(1)** For rules relating to recognition of gain or loss where an exchange is not solely in kind, see subsections (b) and (c) of section 1031.

**(2)** For rules relating to the basis of property acquired in an exchange described in subsection (a), see subsection (d) of section 1031.

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**Source Credit**: (Aug. 16, 1954, ch. 736, 68A Stat. 309; Pub. L. 105–34, title X, § 1014(e)(3), Aug. 5, 1997, 111 Stat. 921.)

## Editorial Notes

### Amendments

1997—Subsecs. (b), (c).  added subsec. (b) and redesignated former subsec. (b) as (c).

## Statutory Notes and Related Subsidiaries

### Effective Date of 1997 Amendment

Amendment by  applicable, with certain exceptions, to transactions after , see , set out as a note under .