The Code of Federal Regulations of the United States of AmericaU.S. Government Printing Office, 1976 - Administrative law The Code of Federal Regulations is the codification of the general and permanent rules published in the Federal Register by the executive departments and agencies of the Federal Government. |
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Common terms and phrases
accumulated earnings acquiring corporation adjusted basis assets capital loss classes of stock common stock complete liquidation controlled corporation date of distribution December 31 depreciation described in section determined distributing corporation distribution or transfer distributor or transferor dividend carryover earnings and profits election erty excess fair market value Federal feror corporation following examples gain or loss graph holders Internal Revenue Code January June 30 liability loss corporation method of accounting method of taking operating loss carryovers outstanding stock ownership paragraph percent in value plan of liquidation poration postacquisition preferred stock provided in section provisions of section purchase purposes of section pursuant quiring recognized referred respect sale or exchange section 301 applies section 306 stock shareholder Statutory provisions stock of Corporation stock or securities subchapter subparagraph subsection taxable income taxable year beginning taxable year ending tion trade or business transaction transferor corporation treated tribution unused X Corporation
Popular passages
Page 137 - No gain or loss shall be recognized if stock or securities in a corporation a party to a reorganization are, in pursuance of the plan of reorganization, exchanged solely for stock or securities in such corporation or in another corporation a party to the reorganization.
Page 146 - ... (2) If a distribution made in pursuance of a plan of reorganization is within the provisions of paragraph (1) of this subsection but has the effect of the distribution of a taxable dividend, then there shall be taxed as a dividend to each distributee such an amount of the gain recognized under paragraph (1) as is not in excess of his ratable share of the undistributed earnings and profits of the corporation accumulated after February 28, 1913. The 'remainder, if any, of the gain recognized under...
Page 16 - This paragraph shall not apply to any redemption made pursuant to a plan the purpose or effect of which is a series of redemptions resulting in a distribution which (in the aggregate) is not substantially disproportionate with respect to the shareholder. (3) Termination of shareholder's interest. Subsection (a) shall apply if the redemption is in complete redemption of all of the stock of the corporation owned by the shareholder.
Page 136 - In exchange consists not only of property permitted by such paragraph to be received without the recognition of gain, but also of other property or money, then the gain, If any, to the recipient shall be recognized, but In an amount not In excess of the sum of such money and the fair market value of such other property.
Page 101 - 2) within the 12-month period beginning on the date of the adoption of such plan, all of the assets of the corporation are distributed In complete liquidation, less assets retained to meet claims, then no gain or loss shall be recognized to such corporation from the sale or exchange by It of property within such 12-month period. (b) Property Defined. — (1) In General. — For purposes of subsection (a), the term 'property...
Page 95 - ... (B) stock of the distributing corporation possessing at least 80 percent of the total combined voting power of all classes of stock entitled to vote, and at least 80 percent of the total number of shares of all other classes of stock (except nonvoting stock which is limited and preferred as to dividends...
Page 158 - Immediately before the acquisition) ; (C) the acquisition by one corporation. In exchange solely for all or a part of Its voting stock (or In exchange solely for all or a part of the voting stock of a corporation which Is In control of the acquiring corporation...
Page 156 - ... corporation which is in control of the acquiring corporation, of substantially all of the properties of another corporation, but in determining whether the exchange is solely for stock the assumption by the acquiring corporation of a liability of the other, or the fact that property acquired is subject to a liability, shall be disregarded...
Page 108 - ... formed or availed of, with a view to— (A) the sale or exchange of stock by its shareholders (whether in liquidation or otherwise), or a distribution to its shareholders, before the realization by the corporation manufacturing, constructing, producing, or purchasing the property of a substantial part of the taxable income to be derived from such property, and (B) the realization by such shareholders of gain attributable to such property.
Page 142 - ... controlled corporation") which it controls immediately before the distribution, (B) the transaction was not used principally as a device for the distribution of the earnings and profits of the distributing corporation or the controlled corporation or both...