CorpTax-Slides for Chapter 5.Fall13

Contribution to capital applies to sales exchanges

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Unformatted text preview: lan of liquidation in a § 351 transaction or a contribution to capital Applies to sales, exchanges, and liquidating distributions The amount of the disallowed loss is the lesser of the built in loss or the realized loss. Loss attributable to the holding period of the liquidating corporation can be recognized 5 Loss Disallowance Rules—§ 336(d)(3) All losses (including losses on distributions to minority shareholders) are disallowed if § 332 applies to any recipient 6 Complete Liquidations—§ 331 Amounts received in complete liquidation of a corporation are treated as full payment in exchange for the shareholder’s stock A shareholder’s amount realized is the FMV of the assets received less liabilities A shareholder’s recognized gain is the amount realized less the shareholder’s basis in the stock Gain or loss is computed on a per-share basis Timing of gain or loss recognition In general – cost recovery method 7 Complete Liquidations—§ 334(a)—Basis Basis of property received in complete liquidation under § 331, is the FMV of the property received 8 Liquidations under § 332 and § 337 Tax consequences to the liquidating corporation—§ 3...
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This note was uploaded on 04/04/2014 for the course ACCT 7375 taught by Professor Staff during the Fall '08 term at University of Houston.

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