The Portfolio also discusses the tax treatment of liquidations before the repeal of that doctrine. Price: 0 Print Tax Management Portfolio, Corporate Liquidations, No. Treatment of Liquidating Corporation - General Rule a.
Section 337 - Tax Consequences to Subsidiary (1) Subsidiary Not Taxable on Distributions to Parent with Respect to Stock (2) Subsidiary Not Taxable on Transfers in Satisfaction of Debt to Parent (3) Subsidiary Taxable on Certain Distributions to a Tax-Exempt Parent c. Basic Requirements of Nontaxable Subsidiary Liquidations A.
Requirement of Distribution with Respect to Stock 2. Tax Consequences to Insolvent Subsidiary on Cancellation of Debt in Liquidation 4. Section 332 Does Not Protect Parent from Gain or Loss b. Consequences of Subsidiary's Ownership of Parent Debt if § 332 Does Not Apply a.
Noncompliance with Regulatory Procedural Requirements d. Delay of Liquidating Distributions Beyond Three Years e. Tax Treatment of Intercorporate Debt in a Liquidation of a Subsidiary A. Consequences to Parent of Repayment from Subsidiary a. Distributions to Minority Shareholders and to Tax-Exempt 80% Distributees A.
Tax Management Portfolio, Corporate Liquidations, No. 784-3rd, analyses the tax considerations in connection with the liquidation of a corporation.
The principal focus of the Portfolio is on liquidations after the repeal of the General Utilities doctrine by the Tax Reform Act of 1986.