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--No gain or loss shall be recognized to the liquidating corporation on the distribution to the 80-percent distributee of any property in a complete liquidation to which 26 U.S.C. applies, and. L. 96–471, § 2(c)(2), 94 Stat. Nonrecognition for property distributed to parent in complete liquidation of subsidiary. The rules in this part apply to investigations under section 337 of the Tariff Act of 1930 and related proceedings. FCC Again Rejects Net Neutrality Even as Controversy Reignites. For purposes of this section (1) 12-month acquisition period. 2803, related to gain or loss on sales or exchanges in connection with certain liquidations, prior to repeal by Pub. --Except as provided in subparagraph (B), paragraph (1) and subsection (a) shall not apply where the 80-percent distributee is an organization (other than a cooperative described in Subparagraph (A) shall not apply to any distribution of property to an organization described in section 511(a)(2) if, immediately after such distribution, such organization uses such property in an activity the income from which is subject to tax under section 511(a). §§1333, 1335, and 1337) and sections 2 and 1342(d)(1)(B) Nonrecognition for property distributed to parent in … Internet Explorer 11 is no longer supported. 337. Focuses on corporate liquidations under sections 337 and 333 of the U.S. Internal Revenue Code of 1954.  For purposes of this section, the determination of whether any corporation is an 80-percent distributee shall be made without regard to any consolidated return regulation. L. 100–647, § 1006(e)(4)(C), substituted “an activity referred to in clause (i)” for “an unrelated trade or business of such organization”. CHAPTER 2-D. (b)(2)(B)(i). Board of Tax Appeals' finding of overpayment upon appeal from assessment. If any property distributed in the liquidation is subject to a liability or the shareholder assumes a liability of the liquidating corporation in connection with the distribution, for purposes of subsection (a) and section 337, the fair market value of such property shall be treated as not less than the amount of such liability. 1988—Subsec. If any property to which clause (i) applied is disposed of by the organization acquiring such property, notwithstanding any other provision of law, any gain (not in excess of the amount not recognized by reason of clause (i)) shall be included in such organization’s unrelated business taxable income. for purposes of this section and --The Secretary shall prescribe such regulations as may be necessary or appropriate to carry out the purposes of the amendments made by subtitle D of title VI of the Tax Reform Act of 1986, including--, (1) 1987—Subsec. 7. (d), is Pub. 1337), provides that unfair methods of competition and unfair acts in the importation of articles into the United States, or in their sale for importation, or sale within the United States after importation, are unlawful. Pub. 171, Part II, Section 22I. (c) relating to special rules for coordination with section 337 where purchasing corporation holds less than 100 percent of stock, and in case of certain redemptions where an election is made under this section. § 58.1-337. . From a corporation to its stockholders upon complete or partial liquidation of the corporation in a transaction which qualifies for income tax treatment pursuant to § 331, 332, 333, or 337 of the Internal Revenue Code … Subsec. Exception where property will be used in unrelated business, The Secretary shall prescribe such regulations as may be necessary or appropriate to carry out the purposes of the amendments made by subtitle D of title VI of the, “The amendment made by subparagraph (A)(ii) [amending this section] shall not apply to any reorganization if before, Subchapter C. Corporate Distributions and Adjustments, Pub. No gain or loss shall be recognized to the liquidating corporation on the distribution to the 80-percent distributee of any property in a complete liquidation to which section 332 applies. . (1), substituted “this subchapter) or through the use of a regulated investment company, real estate investment trust, or tax-exempt entity” for “this subchapter)”. The Regulations generally provide that under either of two scenarios, a taxable event will be incurred at the corporate level: (a) a taxable corporation transfers all or substantially all of its assets to one or more tax-exempt entities (Asset Sale Rule), or (b) a taxable corporation changes its status to a tax-exempt entity (Chang… Copyright © 2020, Thomson Reuters. Code Section 337(d) Subscribe to Code Section 337(d)'s Posts. 2254; Dec. 24, 1980, Pub. 3628; Apr. McDermott’s Real-Time Tax Disputes Insights. FEDERAL INCOME TAX: INVOLUNTARY CONVERSIONS AS SECTION 337 SALES OR EXCHANGES THE 1954 Internal Revenue Code contains an important innovation in section 337(a), which relates to taxation of gains and losses on the sale and exchange of … § 337 - U.S. Code - Unannotated Title 26. We recommend using From a corporation to its stockholders upon complete or partial liquidation of the corporation in a transaction which qualifies for income tax treatment pursuant to § 331, 332, 333, or 337 of the Internal Revenue Code as it exists at the time of liquidation; 8. Internal Revenue Code Section 338(h)(10) Certain stock purchases treated as asset acquisitions. section 521 Section 337(a) provides that a liquidating corporation recognizes no gain or loss on the distribution to the 80-percent distributee of any property in a complete liquidation to which section 332 applies. Bloomberg Tax offers full-text of the current Internal Revenue Code free of charge. A prior section 337, acts Aug. 16, 1954, ch. 304; Oct. 19, 1980, Pub. L. 99–514, to which such amendment relates, see section 1019(a) of Pub. applies. FindLaw Codes are provided courtesy of Thomson Reuters Westlaw, the industry-leading online legal research system. L. 97–248, title II, § 224(c)(5), (6), 96 Stat. distributed in complete liquidation of another corporation. a corporation is liquidated in a liquidation to which, on the date of the adoption of the plan of liquidation, such corporation was indebted to the, for purposes of this section and section 336, any transfer of property to the, regulations to ensure that such purposes may not be circumvented through the use of any provision of law or regulations (including the consolidated return regulations and part III of this subchapter) or through the use of a regulated. if, immediately after such distribution, such organization uses such property in an activity the income from which is subject to tax under LIQUIDATIONS UNDER SECTION 337 Theodore M. Garver The Internal Revenue Code of 1954 included a new provision, section 337, which allows the tax-free sale of property by a corporation in the process of liquidation. Are We Opening a Pandora's Box in Criticizing Law Firms Challenging the 2020 Election? (1) In general If property is received by a corporate distributee in a distribution in a complete liquidation to which section 332 applies (or in a transfer described in section 337(b)(1)), the basis of such property in the hands of such distributee shall be the same as it would be in the hands of the transferor; except that, in the hands … the board of directors of a party to the reorganization adopted a resolution to solicit shareholder approval for the transaction, or, the shareholders or the board of directors of a party to the reorganization approved the transaction.”, {'misc': '', 'cleanpath': '/uscode/text/26/337', 'headtext': ' Nonrecognition for property distributed to parent in complete liquidation of subsidiary', 'cfr_titles': [{'title': '26', 'parts': [{'part': '1', 'cleanpath': '/cfr/text/26/part-1', 'headtext': 'INCOME TAXES'}]}], 'section': '337'}. L. 95–600, title VII, § 701(i)(1), 92 Stat. For complete classification of this Act to the Code, see Tables. Subtitle D (§§ 631–634) of title VI of the Tax Reform Act of 1986 enacted sections 336 and 337 of this title, amended sections 26, 311, 312, 332, 334, 338, 341, 346, 367, 453, 453B, 467, 852, 897, 1056, 1248, 1255, 1276, 1363, 1366, 1374, and 1375 of this title, and repealed former sections 333, 336, and 337 of this title. Section 337(a)(1)(B) of the Tariff Act of 1930 declares unlawful "importation into the Untied States, the sale for importation, or the sale within the United States after importation by the owner, importer, or consignee, of articles that - (i) infringe a valid and enforceable United States patent. section 511(a)(2) § 337 (a) In General —. . (d). Code Section 337(d) Subscribe to Code Section 337(d)'s Posts. 489; Oct. 22, 1986, Pub. (h) Definitions and special rules. FindLaw Codes may not reflect the most recent version of the law in your jurisdiction. ) which is exempt from the tax imposed by this chapter. (2)  regulations providing for appropriate coordination of the provisions of this section with the provisions of this title relating to taxation of foreign corporations and their shareholders. L. 96–589, § 5(c), 94 Stat. Begin typing to search, use arrow keys to navigate, use enter to select. § 337 - U.S. Code - Unannotated Title 26. section 332(b) 3405; Sept. 3, 1982, Pub.  on the date of the adoption of the plan of liquidation, such corporation was indebted to the 80-percent distributee. L. 100–647, title I, § 1006(e)(5)(B), Nov. 10, 1988, 102 Stat. For purposes of the preceding sentence, an election under section 338(g) of the Internal Revenue Code of 1986 (or an election under section 338(h)(10) of such Code qualifying as a section 337 liquidation pursuant to regulations prescribed by the Secretary under section 1.338(h)(10)-1T(j)) made in connection with a sale or … (a) In general. , any transfer of property to the 80-percent distributee in satisfaction of such indebtedness shall be treated as a distribution to such distributee in such liquidation. (i) In general. Treatment of indebtedness of subsidiary, etc. (B) Prior to the adoption of the 1954 Code, the law was marked by the confusion and unfairness inherent in the decisions of Except as provided in subparagraph (B), paragraph (1) and subsection (a) shall not apply where the 80-percent distributee is an organization (other than a cooperative described in section 521) which is exempt from the tax imposed by this chapter. . 7. (g)(3) of this section the amendments made by section 225 of Pub. L. 99–514, title XVIII, § 1804(e)(7)(A), 100 Stat. Exemption from tax of certain property from outside continental limits of United States. A Section 338(h)(10) election is much more common than a Section 338(g) election because the 338(g) election results in two levels of tax, whereas a 338(h)(10) election results in only one. Insight on the tax consequences of a complete liquidation to the shareholders of a corporation; Requirements of Section 337; Basis of tax imposed on shareholders under section 333. HISTORY: 1962 Code Section 65-1257; 1952 Code Section 65-1257; 1945 (44) 337; 1991 Act No. Nonrecognition For Property Distributed To Parent In Complete Liquidation Of Subsidiary. RS 47:337.96 — Uniform local sales tax administrative code and louisiana register; publication; index RS 47:337.97 — Judicial review of validity or applicability of rules RS 47:337.98 — Appeals U.S. GAAP Codification, U.S. Tax Code by Section: Financial Accounting, Intermediate Accounting, Advanced Accounting: IFRS-U.S. GAAP Comparison, Securities Law Library: USC Title 26 enacted through 2008 § 337. L. 100–647 effective, except as otherwise provided, as if included in the provision of the Tax Reform Act of 1986, Pub. L. 85–866, title I, § 19, 72 Stat. Any individual engaged in agricultural production for market who has in place a nutrient management plan approved by the local Soil and Water Conservation District by the required tax return filing date of the individual shall be allowed a credit against the tax imposed by § 58.1-320 of an … Except as otherwise provided in this section or section 337, gain or loss shall be recognized to a liquidating corporation on the distribution of property in complete liquidation as if such property were sold to the distributee at its fair market value. Prior to the adoption of the 1954 Code, the law was marked by the confusion and unfairness inherent in the … In addition, the Commission may issue cease and desist orders against named importers and other persons engaged in …  regulations to ensure that such purposes may not be circumvented through the use of any provision of law or regulations (including the consolidated return regulations and part III of this subchapter) or through the use of a regulated investment company, real estate investment trust, or tax-exempt entity, and. --For purposes of this section, the term “80-percent distributee” means only the corporation which meets the 80-percent stock ownership requirements specified in section 332 HISTORY: 1962 Code Section 65-1257; 1952 Code Section 65-1257; 1945 (44) 337; 1991 Act No. Treasury Releases Report on Reducing Tax Regulatory Burdens. 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