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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. Distribution Solely of Cash Qualifies as â€œPropertyâ€ E. Subsidiary Liquidations Not Qualifying Under § 332 A. Finally, the Portfolio reviews the issues arising from the liquidation of insolvent subsidiaries and the existence of intercorporate debt in subsidiary liquidations. 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.
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.
Application of Collapsible Corporation Rules to Minority Shareholders 5. Tax Consequences to Liquidating Subsidiary of Distributions to Minority Shareholders 1.
Prior Ownership of Target Stock by Acquirer - Elimination of the â€œBausch & Lombâ€ Rule 4.
Application of § 267(f) to Transfers in Satisfaction of Debt 3.
Recognition of Gain or Loss to Subsidiary if § 332 Does Not Apply to the Liquidation c.