Nontaxable Liquidation of Subsidiary if § 338 Election Is Made 1. Miscellaneous Considerations in a Subsidiary Liquidation A. Section 384: Limitations on Use of Built-In Gains of Acquired Subsidiary 6. Expenses of Subsidiary in Assisting or Resisting a Takeover Attempt a. Subsidiary's Expenses in Redeeming Stock or in Liquidating 7. Consolidated Returns - Excess Loss Accounts and Other Issues 1. Succession to Income Tax Liabilities of Subsidiary's Former Consolidated Group 5. Treatment Upon Liquidation of Subsidiary of Parent's Previously Capitalized Cost of Acquiring Subsidiary 6. Inclusion of Transitory Subsidiary in Consolidated Return 4. Qualification of an S Corporation as a Corporate Parent in a § 332 Liquidation 1.
Section 337 - Tax Consequences to Subsidiary (1) Subsidiary Not Taxable on Distributions to Parent with Respect to Stock (2) Subsidiary Not Taxable on Transfers in Satisfaction of Debt to Parent (3) Subsidiary Taxable on Certain Distributions to a Tax-Exempt Parent c. Basic Requirements of Nontaxable Subsidiary Liquidations A.
Distribution Solely of Cash Qualifies as â€œPropertyâ€ E.
Subsidiary Liquidations Not Qualifying Under § 332 A.
Requirement of Distribution with Respect to Stock 2. Tax Consequences to Insolvent Subsidiary on Cancellation of Debt in Liquidation 4. Section 332 Does Not Protect Parent from Gain or Loss b. Consequences of Subsidiary's Ownership of Parent Debt if § 332 Does Not Apply a.
Noncompliance with Regulatory Procedural Requirements d. Delay of Liquidating Distributions Beyond Three Years e. Tax Treatment of Intercorporate Debt in a Liquidation of a Subsidiary A. Consequences to Parent of Repayment from Subsidiary a. Distributions to Minority Shareholders and to Tax-Exempt 80% Distributees A.
General Rule in Nontaxable Liquidation of a Subsidiary 1.