The Code of Federal Regulations of the United States of AmericaU.S. Government Printing Office, 1994 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 ADSP AGUB allocated amount assets capital loss carrybacks 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 domestic corporation earnings and profits erty Example fair market value Federal Acquisition Regulation feror ferred filed foreign corporation gain or loss graph inventories issuance January June 30 liability liquidation loss corporation method of accounting option owner ownership interest poration postacquisition pre-change preferred stock pursuant qualified stock purchase quiring recognize gain reorganization respect rules of paragraph section 338 election shares spect stock of Corporation stock or securities subparagraph taken into account taxable income taxable year ending testing date tion trade or business trans transaction transferor corporation treated tribution U.S. person X Corporation
Popular passages
Page 252 - ... 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.
Page 54 - ... distributed in a distribution or exchange to which section 355 (or so much of section 356 as relates to section 355) applies...
Page 67 - Amounts distributed in complete liquidation of a corporation shall be treated as in full payment in exchange for the stock, and amounts distributed in partial liquidation of a corporation shall be treated as in part or full payment in exchange for the stock.
Page 240 - Code is to except from the general rule certain specifically described exchanges incident to such readjustments of corporate structures. made in one of the particular ways specified in the Code, as are required by business exigencies and which effect only a readjustment of continuing interest in property under modified corporate forms.
Page 261 - 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 159 - 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 69 - Is made; and for purposes of this subsection 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 155 - ... 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 155 - ... period immediately before the distribution, which trade or business was not acquired by the corporation within such period in a transaction in which gain or loss was recognized...
Page 202 - ... (3) a copyright, a literary, musical, or artistic composition, a letter or memorandum, or similar property, held by— (A) a taxpayer whose personal efforts created such property...