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DISTRIBUTIONS AND LIQUIDATING SALES OF APPRECIATED
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accumulated earnings acquiring corporation acquisitions additional Administration proposal amount assets basis boot capital gains rates capital gains tax carryover Code Cong contend corporate earnings corporate level tax corporate rate corporate shareholder corporate tax corporation’s debt deferral dends paid depreciation difﬁcult discharge discussed divi dividends paid deduction dividends received deduction earnings and proﬁts effect election eliminate entity equity example extent fair market value ﬁrst foreign shareholders foreign tax credit holders imposed Internal Revenue Service investment Joint Committee Law and Background liability LIFO limited liquidating distributions nonliquidating distributions ordinary income permit porate Possible Proposal preference items present law purchase qualiﬁed redemption reduce reﬂect relief reorganization repeal Reporter’s section 337 Senate Sess shareholder credit shareholder level shareholder’s speciﬁed Subchapter tax beneﬁt tax rate tax-exempt tax-free taxable income Taxation of Corporations taxpayers tion transactions transferor corporation treated two-tier tax U.S. corporation U.S. tax Utilities rule withholding tax