Liquidating llc

General Rule in Nontaxable Liquidation of a Subsidiary 1.

Tax Basis and Holding Period to Parent of Property Received in Liquidation of a Subsidiary A.

The Portfolio also discusses the tax treatment of liquidations before the repeal of that doctrine.

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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.

Addressing liquidations of subsidiaries under §332 (where the parent corporation owns at least 80% of the stock of the subsidiary) as well as liquidations of corporations that do not qualify under §332, the Portfolio considers the tax consequences to both the liquidating corporation and its shareholders. D., The Ohio State University Moritz College of Law; LL. Taxation, Georgetown University Law Center; Former Law Clerk to Hon.

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.

Liquidating Distribution to Preferred But Not to Common Stock - Spaulding Bakeries, Inc. Subsidiary Not Taxable if § 332 Applies to the Liquidation b.

Tax Consequences to Parent on Liquidation of Insolvent Subsidiary a. Qualification of an Insolvent Subsidiary for a Nontaxable Liquidation D. Determining Whether a Taxable Liquidation Is Advantageous 2. Consequences Before Liquidation if Parent Acquires Debt from Unrelated Party c. Consequences to Subsidiary of Repayment of Debt to Parent a.

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