The Code of Federal Regulations of the United States of AmericaU.S. Government Printing Office, 1988 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 acquiring corporation acquisition date adjusted basis adjusted grossed-up basis ADSP allocated amount assets capital loss carrybacks class of stock common stock computed Corporation's date of distribution December 31 deduction deemed sale described in section determined distribution or transfer distributor or transferor dividend earnings and profits election under section Example express election fair market value February 28 filed foreign corporation gain or loss graph intangible property inventories January June 30 liability loss carryovers loss corporation method of accounting operating loss ordinary income outstanding stock ownership change ownership interest percent period poration preferred stock public group purposes pursuant qualified stock purchase quiring ration redemption reorganization respect ryovers section 338 election shares stock of Corporation stock or securities subparagraph target affiliate taxable income taxable year ending tier entity tion trade or business trans transaction transferor corporation treated U.S. person X Corporation
Popular passages
Page 49 - control" means the ownership of stock 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 of the corporation.
Page 272 - No gain or loss shall be recognized If a corporation a party to a reorganization exchanges property, in pursuance of the plan of reorganization, solely for stock or securities in another corporation a party to the reorganization.
Page 470 - A corporation has not continued to carry on a trade or business substantially the same as that conducted before...
Page 261 - ... used principally as a device for the distribution of the earnings and profits of the distributing corportion or of the controlled corporation, or both.
Page 60 - ... and immediately thereafter the stock and securities of the controlled corporation are distributed in a distribution or exchange to which section 355 (or so much of section 356 as relates to section 355) applies, the earnings and profits of the distributing corporation immediately §1.312-11 before the transaction shall be allocated between the distributing corporation and the controlled corporation.
Page 333 - The portion of such loss which shall be carried to each of the other taxable years shall be the excess, If any, of the amount of such loss over the sum of the taxable Income for each of the prior taxable years to which such loss may be carried.
Page 252 - 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 252 - Partial liquidation defined — (a) In general. For purposes of this subchapter, a distribution shall be treated as in partial liquidation of a corporation if — (1) The distribution is one of a series of distributions in redemption of all of the stock of the corporation pursuant to a plan...
Page 227 - ... determination shall be made by reference to the aggregate of the properties constituting the single project. (5) A corporation shall be deemed to have manufactured, constructed, produced, or purchased property if it (i) engaged in the manufacture, construction, or production of property to any extent, or (ii) holds property having a basis determined, in whole or in part, by reference to the cost of such property in the hands of a person who manufactured, constructed, produced, or purchased the...
Page 253 - Gain (if any) to such recipient shall be recognized, but not in excess of — (A) The amount of money received, plus (B) The fair market value of such other property received; and (2) No loss to such recipient shall be recognized. (c) Special rule.