The Code of Federal Regulations of the United States of AmericaU.S. Government Printing Office, 1998 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
5-percent shareholder accumulated earnings acquiring cor acquiring corporation acquisition date adjusted basis AGUB allocated amended amount assets capital loss carrybacks cash class of stock common stock computed controlled corporation corporation's date of distribution December 31 deduction deemed sale described in section disposition distributing corporation distribution or transfer distributor or transferor dividend domestic corporation earnings and profits erty Example fair market value Federal Acquisition Regulation ferred filed gain or loss graph holder inventories issuance January June 30 liability liquidation loss corporation ment merger method of accounting option ownership interest period poration postacquisition pre-change preferred stock pursuant quiring recognize gain redemption reorganization respect rules of paragraph section 338 election shares spect stock of Corporation stock or securities subparagraph target corporation taxable income taxable year ending testing date tier entity tion trade or business trans transaction transferor corporation treated tribution U.S. person X Corporation
Popular passages
Page 153 - ... 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 60 - February 28, 1913, or (2) out of its earnings and profits of the taxable year (computed as of the close of the taxable year without diminution by reason of any distributions made during the taxable year), without regard to the amount of the earnings and profits at the time the distribution was made.
Page 56 - 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 278 - Permanent records in substantial form shall be kept by every taxpayer who participates in a tax-free exchange in connection with a corporate reorganization 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...
Page 161 - ... 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 10 - A distribution made by a corporation to its shareholders shall be included in the gross income of the distributees when the cash or other property is unqualifiedly made subject to their demands.
Page 219 - capital assets" means property held by the taxpayer (whether or not connected with his trade or business), but does not include stock in trade of the taxpayer or other property of a kind which would properly be included in the inventory of the taxpayer if on hand at the close of the taxable year, or property held by the taxpayer primarily for sale to customers in the ordinary course of his trade or business...
Page 139 - ... owned stock which was considered as owned at such time by another shareholder who then owned (or was considered as owning) more than 5 percent in value of the outstanding stock of the corporation...
Page 57 - ... party to the reorganization, stock or securities in such corporation or in another corporation a party to the reorganization, without the surrender by such shareholder of stock or securities in such a corporation, no gain to the distributee from the receipt of such stock or securities shall be recognized.
Page 278 - ... increased in the amount of gain or decreased in the amount of loss recognized to the grantor upon such transfer under the law applicable to the year in which the transfer was made.