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Unformatted text preview: or contribution to capital transaction • Acquisition was part of a plan whose principal purpose was to recognize a loss on that property by the liquidating corporation (presumed in cases of transfers occurring within 2 years of the adoption of a plan of liquidation) Subsidiary corporation does not recognize gains or losses on liquidating distributions to its parent corporation §332 Subsidiary corporation does not recognize losses on liquidating distributions to its minority shareholders §332 • Shareholder §331(a) o FMV of property received-basis in stock Realized gain Recognized gain (capital gain) = realized gain o Basis in property received = FMV of property received...
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- Spring '10
- Subsidiary, Conglomerate, subsidiary corporation, Subsidiary corporation