CorpTax-Slides for Chapter 5.Fall13

Only applies to the actual property transferred to

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Unformatted text preview: appears 11 Minority Interest Tax consequences to the liquidating corporation Nonrecognition of gain or loss under § 337 only applies to the actual property transferred to the parent Actual property transferred to the minority shareholders is governed by § 336 § 336 requires recognition of gain, however, no loss will be recognized because of § 336(d)(3) 12 Minority Interest (Cont’d) Tax consequences to the recipients The parent corporation will be governed by § 332 (no gain or loss) and § 334(b)(1) (transferred basis) The minority shareholders will be governed by § 331 (sale of stock) and § 334(a) (FMV basis) 13 Questions about End-of-Chapter Problems for Chapter 5? 14...
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