§ 1.337-1. Nonrecognition for property distributed to parent in complete liquidation of subsidiary.
104 words·~1 min read·
/us/cfr/t26/s§ 1.337-1·A research copy — for the controlling text, always check the official state or federal source. Not legal advice.
(a)General rule. If sections 332(a) and 337 are applicable with respect to the receipt of a subsidiary`s property in complete liquidation, no gain or loss is recognized to the liquidating subsidiary with respect to such property (including property distributed with respect to indebtedness, see section 337(b)(1) and § 1.332-7), except as provided in section 337(b)(2) (distributions to certain tax-exempt distributees), section 367(e)(2) (distributions to foreign corporations), and section 897(d) (distributions of U.S. real property interests by foreign corporations).
(b)Applicability date. This section applies to any taxable year beginning on or after March 28, 2016. [T.D. 9759, 81 FR 17074, Mar. 28, 2016]
Connections1 off-index
1 reference not yet in our index
- T.D. 9759
Citation graph
cites case law
§ 1.337-1
Nonrecognition for property distributed to parent in complete liquidation of subsidiary.
Treas. Dec.T.D. 9759
Cites 1Cited by 0 across 0 sources