The Code of Federal Regulations of the United States of AmericaU.S. Government Printing Office, 1973 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
20 percent accumulated earnings acquiring corporation adjusted basis applies capital loss 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 erty excess fair market value February 28 Federal feror corporation following examples gain or loss graph holders Internal Revenue Code January June 30 liability loss corporation method of accounting operating loss carryovers operating loss deduction outstanding stock ownership paragraph percent in value personal holding company plan of liquidation plan of reorganization poration postacquisition preceding taxable preferred stock provided in section provisions of section purchase pursuant quiring recognized respect sale or exchange 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 X Corporation
Popular passages
Page 128 - If an exchange would be within the provisions of subsection (b) (1), (2), (3), or (5) of this section if it were not for the fact that the property received 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...
Page 56 - For purposes of this subtitle, the term "dividend" means any distribution of property made by a corporation to its shareholders — (1) Out of its earnings and profits accumulated after 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 129 - ... 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 paragraph (1) shall be taxed as a gain from the exchange of property.
Page 208 - Secretary, expended in the acquisition of other property similar or related in service or use to the property so converted, or in the acquisition of control of a corporation owning such other property, or in the establishment of a replacement fund, no gain or loss shall be recognized. If any part of the money is not so expended...
Page 144 - If It were not for the fact that the property received 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 53 - ... (b) Source of distributions. For the purposes of this Act every distribution is made out of earnings or profits to the extent thereof, and from the most recently accumulated earnings or profits.
Page 82 - ... (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 95 - In paragraph (3) , or for the holding of stock In a corporation so 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...
Page 144 - ... to be received without the recognition of gain or loss, but also of other property or money, then no loss from the exchange shall be recognized.
Page 62 - His spouse (other than a spouse who Is legally separated from the Individual under a decree of divorce or separate maintenance) , and (II) His children, grandchildren and parents.