The Code of Federal Regulations of the United States of AmericaU.S. Government Printing Office, 1971 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 applies common stock complete liquidation controlled corporation date of distribution December 31 described in section determined distribution or transfer distributor or trans 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 redemption respect sale or exchange section 306 stock section 381 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 74 - ... (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 131 - It has been established to the satisfaction of the Secretary or his delegate that such exchange Is not In pursuance of a plan having as one of its principal purposes the avoidance of Federal Income taxes.
Page 121 - 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 137 - 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 122 - ... 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 116 - Such trade or business has been actively conducted throughout the 5-year period ending on the date of the distribution, (C) Such trade or business was not acquired within the period described in subparagraph (B) in a transaction in which gain or loss was recognized in whole or In part...
Page 132 - ... the acquisition by one corporation, in exchange solely for all or a part of its voting stock...
Page 79 - Gain or loss on sales or exchanges in connection with certain liquidations. (a) General Rule — If — (1) a corporation adopts a plan of complete liquidation on or after June 22, 1954, and (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...
Page 22 - For purposes of this section, 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.
Page 229 - ... such corporation has not continued to carry on a trade or business substantially the same as that conducted before...