This preview shows page 1. Sign up to view the full content.
Unformatted text preview: receivable (I/R), then distributes the I/R (note) to the shareholder) SALE: Gain/loss realized = Parent recognizes NO gain OR loss S/Hs AB in Property Recd FMV Carryover basis Effect on Distributing Corps Taxable Income Gains AND losses recognized EXCEPTION: Related-party losses disallowed per Sec. 336(d)(1); tax-avoidance losses limited per Sec. 336(d) (2) NO gain OR loss recognized Effect on Distributing Corps E&P and Tax Attributes E&P eliminated; other tax attributes disappear No E&P effect since carryover basis AND parent inherits subsidiarys attributes...
View Full Document
This note was uploaded on 03/25/2012 for the course TAX 3011 taught by Professor Jones during the Spring '12 term at UNF.
- Spring '12