Chapter 15 corporate nonliquidating distributions
You’ll get the deep understanding of complex tax matters you need to make the best tax decisions and develop the best corporate tax strategies.
The trusted guidance found in this resource is cited in more than a dozen decisions by the U. Supreme Court; is found in nearly 500 opinions by the federal courts; and is included in more than 250 IRS rulings.
The corporation does not recognize gain or loss when it distributes cash to shareholders or when it redeems stock in exchange for cash payments (Sec. When a corporation makes a nonliquidating distribution of corporate property other than cash (including a distribution to redeem stock), the corporation recognizes gain if the property’s fair market value (FMV) exceeds its adjusted tax basis in the corporation’s hands (Sec. Specifically, the corporation recognizes gain as if it had sold the appreciated property for FMV to the recipient shareholder. The portion of the corporation’s gain attributable to recapture items (e.g., depreciation recapture) is ordinary income, as is gain attributable to the distribution of inventory and unrealized receivables. Form 5452, Corporate Report of Nondividend Distributions, is used to report nondividend distributions to shareholders.
5) When appreciated property is distributed in a nonliquidating distribution, the net effect on the distributing corporation's E&P is that it is reduced by the FMV of the property distributed and increased by the gain (net of federal income taxes) recognized due to the property distribution.
All shipping options assumes the product is available and that it will take 24 to 48 hours to process your order prior to shipping.
Premium content is only available to registered Connect users and is identified in the left-hand Navigation Menu by the asterisk (*) which precedes the content name.
focuses on complete corporate transactions and provides interrelated documents dealing with the various aspects of a specific transaction.
The types of transactions covered include corporate organizations, cash and stock dividends, stock redemptions, partial liquidations, complete liquidations, spin-offs, and tax-free reorganizations.
Search for chapter 15 corporate nonliquidating distributions:
If the property held by a distributed corporation is stock in a corporation which the distributed corporation controls, this subsection shall be applied to reduce the basis of the property of such controlled corporation.