Irc Section 332

The amendments made by this section amending this section and sections 355 358 and 368 of this title shall not apply to any distribution pursuant to a plan or series of related transactions which involves an acquisition described in section 355 e 2 a ii of the internal revenue code of 1986 or in the case of the amendments made by.

Irc section 332. Paragraph a 3 of this section applies with respect to liquidations under section 332 occurring on or after march 28 2016. Amendment by section 631 e 2 of pub. Under section 332 the parent corporation assumes the tax attributes of the subsidiary as well as its inside tax basis in its assets and its holding period for those assets.

1 1987 any transaction described in section 338 of this title for which the acquisition date occurs after dec. 99 514 applicable to any distribution in complete liquidation and any sale or exchange made by a corporation after july 31 1986 unless such corporation is completely liquidated before jan. For taxable years beginning before may 30 2006 see 1 332 6 as contained in 26 cfr part 1 in effect on april 1 2006.

G 3 of this section the amendments made by section 225 of pub. To qualify under section 332 the parent must own both 80 of the total voting power of the corporation s stock and 80 of the total value of the corporation s stock. 1 1987 any transaction described in section 338 of this title for which the acquisition date occurs after.

88 272 do not apply if there is a complete liquidation of such corporation and if the distribution of all the property under such liquidation occurs before jan. Section applicable to any distribution in complete liquidation and any sale or exchange made by a corporation after july 31 1986 unless such corporation is completely liquidated before jan. 1 1966 except for certain liquidations to which section 332 of this title applies.

Amendment by section 631 e 2 of pub. 1 1987 any transaction described in section 338 of this title for which the acquisition date occurs after dec. 88 272 do not apply if there is a complete liquidation of such corporation and if the distribution of all the property under such liquidation occurs before jan.

1 1966 except for certain liquidations to which section 332 of this title applies. See 26 cfr 1939 39 22 a 20 regulations 118 d if a transaction constitutes a distribution in complete liquidation within the meaning of the internal revenue code of 1954 and satisfies the requirements of section 332 it is not material that it is otherwise. Internal revenue code 26 usca section 332.