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The Portfolio also discusses the tax treatment of liquidations before the repeal of that doctrine. To view this Portfolio, take a free trial to Bloomberg BNA Tax & Accounting This Portfolio is available with a subscription to Bloomberg BNA Tax & Accounting, a comprehensive research solution including over 500 Tax Management Portfolios, practice tools, primary sources and timely news. Qualification of an S Corporation as a Corporate Parent in a § 332 Liquidation 1. Assignment of Income Doctrine and the Tax Benefit Rule 2.
Section 332 - Tax Consequences to Parent (1) Parent's Receipt of Property with Respect to Stock Is Nontaxable (2) Parent's Receipt of Property in Satisfaction of Debt Is Taxable b. Section 334 - Shareholdersâ€™ Basis in Property Received in Liquidation II.
Section 382: Limitation on Loss Carryovers and Built-In Losses 4. Deduction of Organizational, Liquidation, and Dissolution Expenses 1.
Expenses of Subsidiary in Assisting or Resisting a Takeover Attempt a.
Tax Consequences to Parent on Liquidation of Insolvent Subsidiary a. Qualification of an Insolvent Subsidiary for a Nontaxable Liquidation D. Determining Whether a Taxable Liquidation Is Advantageous 2. Consequences Before Liquidation if Parent Acquires Debt from Unrelated Party c. Consequences to Subsidiary of Repayment of Debt to Parent 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.
The Portfolio highlights traps for unwary taxpayers and discusses planning opportunities in connection with a corporate liquidation.