26 CFR § 1.356-5
Transactions involving gift or compensation
June 25, 2020
With respect to transactions described in sections 354, 355, or 356, but which—
(a) Result in a gift, see section 2501 and following, and the regulations pertaining thereto, or
(b) Have the effect of the payment of compensation, see section 61(a)(1), and the regulations pertaining thereto.