Code of Federal Regulations: Containing a Codification of Documents of General Applicability and Future Effect as of December 31, 1948, with Ancillaries and IndexDivision of the Federal Register, the National Archives, 1985 Special edition of the Federal Register, containing a codification of documents of general applicability and future effect ... with ancillaries. |
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Common terms and phrases
accumulated earnings acquiring corporation acquisition adjusted basis amount application of section assets attributable bution cash classes of stock common stock complete liquidation computed considered date of distribution December 31 deduction deemed sale date depreciation described in section determined distri distributing corporation distribution or transfer distributor or transferor earnings and profits excess fair market value February 28 filed gain or loss graph holders ings and profits Internal Revenue Code inventories January June 30 liability loss corporation method of accounting operating loss carryovers outstanding stock ownership percent in value percentage points period plan of liquidation poration postacquisition preferred stock purchase pursuant quiring ration received recognized redemption reorganization respect rule ryovers sale or exchange section 306 stock shares of stock stock of Corporation stock or securities subpara subparagraph taxable income taxable year beginning taxable year ending tion trade or business transaction transferor corporation treated tribution X Corporation
Popular passages
Page 75 - ... 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 65 - ... more than 50 percent in value of the outstanding stock of which is owned by the same person. (2) Control. For purposes of this paragraph, control means the ownership of stock possessing at least 50 percent of the total combined voting power of all classes of stock entitled to vote or at least 50 percent of the total value of shares of all classes of stock of the corporation.
Page 65 - ... 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 155 - A corporation has not continued to carry on a trade or business substantially the same as that conducted before any increase in the ownership of its stock if the corporation is primarily engaged in the rendition of services by a particular individual or individuals and, after the increase in ownership, the corporation is primarily engaged in the rendition of services by different individuals. This subparagraph may be illustrated by the following examples: Example (l).
Page 45 - ... possessing at least 80 percent of the total combined voting power of all classes of stock entitled to vote and the owner of 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 86 - Permanent records in substantial form shall be kept by every taxpayer who participates in an exchange described in section 371(b), showing the cost or other basis of the transferred property and the amount of stock or securities and other property or money received (including any liabilities assumed upon the exchange), in order to facilitate the determination of gain or loss from a subsequent disposition of such stock or securities and other property received from the exchange.
Page 72 - ... which trade or business was not acquired by the corporation within such period in a transaction in which gain or loss was recognized in whole or in part.
Page 71 - The distribution is one of a series of distributions in redemption of all of the stock of the corporation pursuant to a plan of complete liquidation, or (2) The distribution: (i) Is not essentially equivalent to a dividend...
Page 46 - ... a transfer of property of such other corporation to the taxpayer shall not be considered as not constituting a distribution (or one of a series of distributions) in complete cancellation or redemption of all the stock of such other corporation, merely because the carrying out of the plan involves...
Page 6 - The amount of any distribution determined under paragraph (1) shall be reduced (but not below zero) by — (A) The amount of any liability of the corporation assumed by the shareholder in connection with the distribution, and (B) The amount of any liability to which the property received by the shareholder is subject immediately before, and immediately after, the distribution.