Section 332 Statement

1 the name and employer identification number if any of the liquidating corporation.

Section 332 statement. 2 the date s of all distribution s whether or not pursuant to the plan by the liquidating corporation during the current tax year. The corporation sought a. In the context of nontaxable corporate liquidations meeting the requirements of sec.

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. Amendment by section 631 e 2 of pub. 1 332 6 requires a parent corporation receiving distributions in complete liquidation from its 80 or more liquidating subsidiary corporation to include a statement on its tax return for that year stating that the corporation received a liquidating distribution and to provide the fair market value and basis of the distributed property immediately before the liquidation.

Given the general rule that u s. 1 1987 any transaction described in section 338 of this title for which the acquisition date occurs after. The statement must include.

If any recipient corporation received a liquidating distribution from the liquidating corporation pursuant to a plan whether or not that recipient corporation has received or will receive other such distributions from the liquidating corporation in other tax years as part of the same plan during the current tax year such recipient corporation must include a statement entitled statement pursuant to section 332 by insert name and employer identification number if any of taxpayer a. 1504 a 2 generally 80 by voting power and value and the distribution was made in complete cancellation or redemption of all the stock of the liquidating corporation. For example fc may liquidate under internal revenue code irc section 332 into its sole owner u s.

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. 332 b provides for nonrecognition of gain or loss where the corporation receiving such property was on the date of adoption of the plan of liquidation and at all times thereafter until the receipt of the property the owner of stock meeting the requirements of sec. 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.

Under code section 332 no gain or loss is recognized by a parent corporation on the receipt of property distributed in complete liquidation of a subsidiary. 332 b liquidations to which section applies for purposes of this section a distribution shall be considered to be in complete liquidation only if. 3 the fair market value and basis of assets of the liquidating corporation that have been or will be transferred to any recipient corporation aggregated as follows.