Corporate Income Taxation
Non-Liquidating Distributions to Shareholders; Liquidation of a Corporation and Taxable Sales or Corporate Businesses; Collapsible Corporations; Retention of Corporate Earnings; Small Businesses; Organization of a Corporation; Corporate Divisions; Reorganizations; Acquisition or Retention of Tax Attributes; Multiple Corporations.
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B Theoretical Overview
Exclusions Deductions and Credits
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301 distribution 382 limitation 5th Cir accumulated earnings acquiring corporation acquisition date adjusted affiliated group allocated amount apply attribution rules Blackacre boot built-in loss Bull capital gains capital loss carryback cash class of stock Commissioner common stock Congress consistency rules consolidated group consolidated return constitute corporate tax corporation's stock debt deemed sale depreciation determining distributing corporation dividend-received deduction earnings and profits example exchange fair market value gain or loss held income tax infra interest investment liquidating distribution loss corporation merger nonrecognition treatment ordinary income outstanding stock parent corporation payment percent percentage PHC income preferred stock prior Proposed Regulations provision purposes pursuant received recognition period recognize gain recognized built-in gain redeemed redemption reduced reorganization requirement Section selling shareholder Subchapter subsidiary supra target corporation tax attributes tax avoidance Tax Court taxable income taxpayer trade or business transaction transfer transferor Treas treated trust voting stock