WebSubpart A. § 332. Sec. 332. Complete Liquidations Of Subsidiaries. I.R.C. § 332 (a) General Rule —. No gain or loss shall be recognized on the receipt by a corporation of property distributed in complete liquidation of another corporation. I.R.C. § 332 (b) Liquidations To Which Section Applies —. For purposes of this section, a ... WebJul 1, 2024 · On Oct. 1, 2024, FC1 makes a $10 distribution to DP and also earns $5 of Subpart F income. At the end of 2024, DP has a Sec. 965 (a) inclusion amount of $20 in relation to FC1's DFI measured on Dec. 31, 2024. Under Regs. Sec. 1.961-1 (a) (1), DP's tax basis in FC1's stock may not be increased by the Sec. 965 (a) inclusion and the Subpart F ...
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WebJun 5, 2024 · The purpose of section 367 (b) in the context of an inbound section 332 liquidation or section 368 reorganization (inbound asset transfer) is to ensure that the … WebInitial Structure Inbound 332 Liquidation Ending Point All FC property Reg. 1.367(b)-3(b)(3)(ii), Example 2 DC, a domestic corporation, owns all of the outstanding stock of FC, a foreign corporation. The stock of FC has a value of $100, and DC has a basis of $30 in such stock. The all earnings and profits amount attributable to the FC lite and easy wa
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