Techcom Inc (TCRI)

[falon]

TCRI 2022


Munaf Ali acquired a US listing entity (TCRI) for the purpose of listing some of the Phoenix Group income generating assets on the US stock market. Expect to share more information in early 2022.

Under Internal Revenue Code §351, no gain or loss is recognized if one or more persons transfer property to a corporation solely in exchange for the stock in the corporation and immediately after the exchange such person or persons are in control of the corporation. The basic requirement for this tax-free exchange is that the transferor or transferors must be in control immediately after the exchange. Control, for this purpose, means the transferor or transferors must have ownership of stock possessing at least 80 percent of the total stock of the corporation. The gain or loss is not recognized when in exchange for the transferred property, the transferor receives the corporation's stock or securities.

Munaf Ali owns 84.7% of TCRI.
https://ch.marketscreener.com/boersen-barone/Munaf-Ali-0H77Y3-E/biography/


A transferor could transfer appreciated property into a corporation without recognizing a gain. For purposes of Internal Revenue Code §351, when a transferor receives securities, such securities will be treated as "boot" in all cases. Boot is other property or money the transferor receives in addition to the stock.

Permitting a nontaxable transfer to a controlled corporation will postpone the recognition of gain or loss until the stock received in the transfer is ultimately disposed of by the transferor. This is accomplished by attributing to the stock the same basis as that of the property originally transferred in exchange. More importantly, the property transferred will retain its basis in the hands of the corporation.

The first step in the transfer process is to form the corporation and the offer by the transferor of the property to the corporation. The courts have held and the Internal Revenue Service has ruled that money qualifies as property in addition to goodwill, patents, and other intangible assets constitute property for this purpose, except services. The second step would be that the corporation's shareholders and the board of directors must accept the offer, and the board of directors must authorize the issuance of the stock upon delivery of the appropriate instruments of conveyance. The final step is the execution and delivery of the instruments of conveyance and property. The importance of formal instruments of transfer, even in the case of a small corporation, cannot be overemphasized. Such instruments are not only a prerequisite to completing the transaction, but can record effectively the price and terms of the transaction.


The current listing is on the OTC however based on the Phoenix's Portfolio, there will be at some point a move to the Nasdaq or other exchange. All in good time.


This is a ground floor opportunity and when Phoenix start moving assets in, this stock will move and move fast.