Liquidating vs nonliquidating distributions
FREE TRIAL Tax Management Portfolio, Corporate Liquidations, No.
Miscellaneous Considerations in a Subsidiary Liquidation A. Section 384: Limitations on Use of Built-In Gains of Acquired Subsidiary 6.
Section 269(b): Liquidation of Recently Purchased Subsidiary 5.
The Portfolio also discusses the tax treatment of liquidations before the repeal of that doctrine.
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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.