Federal Income Tax Project, Subchapter C: Proposals on Corporate Acquisitions and Dispositions, Adopted by the American Law Institute at Washington, D.C., June 13, 1980, and Reporter's Study on Corporate Distributions
This study undertakes to analyse the treatment of corporate acquisitions and distributions in the taxation of corporate and shareholder income under Subchapter C of Chapter 1 of the Internal Revenue Code and to recommend approaches to simplification and imrpovement.
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acquiring corporation acquisition adjustment adopted allocable allowed amount apply assets avoid basis burden capital carry carryover-basis cash combination common complete computation consideration continuing contributed corporate tax cost cost-basis deal debt deduction definition determining direct disposition distribution dividend earnings effect election eliminate equity example exchange excise existing law extent gain or loss hand held imposed individual integration interest investment involves issued kind less liabilities limitation liquidation loss carryovers loss corporation matter merger Moreover nonrecognition operating outstanding ownership paid paragraph parent particular percent permit porate possible preferred premium present prior problems proceeds profits proposal provisions purchase qualified question realized reason received recognized redemption relation reorganization represent require respect result rule selling separate shareholders shares simple specified statutory subsequent subsidiary subsidiary shares substantial taxable income taxfree tion transaction transfer transferor treated treatment