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Nontaxable Liquidation of Subsidiary if § 338 Election Is Made 1.

Miscellaneous Considerations in a Subsidiary Liquidation A. Section 384: Limitations on Use of Built-In Gains of Acquired Subsidiary 6.

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784-3rd, analyses the tax considerations in connection with the liquidation of a corporation. Evolution of the Tax Treatment of Corporate Liquidations B.

The principal focus of the Portfolio is on liquidations after the repeal of the General Utilities doctrine by the Tax Reform Act of 1986. Bar Taxation Section (Section Chair; Member and Former Chair of the Corporate Tax Committee); American Bar Association Tax Section (Vice Chair, Professional Services Committee; Member, Corporate Tax Committee; Member, Government Relations Committee); frequent speaker and author of various tax articles. Legislative History of the Repeal of the General Utilities Doctrine 1.

The Portfolio identifies issues arising in the context of deemed liquidations, and the special problems that can occur as a result of the interplay of the liquidation provisions with the S corporation rules and the consolidated return regulations.

The Portfolio also discusses the relationship between the liquidation rules and §338 (the election to treat a stock purchase as a purchase of assets).

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Tax Management Portfolio, Corporate Liquidations, No. 784-3rd, analyses the tax considerations in connection with the liquidation of a corporation. Application of § 267(f) to Transfers in Satisfaction of Debt 3. Recognition of Gain or Loss to Subsidiary if § 332 Does Not Apply to the Liquidation c. Distribution Solely of Cash Qualifies as “Property” E. Subsidiary Liquidations Not Qualifying Under § 332 A. Requirement of Distribution with Respect to Stock 2. Tax Consequences to Insolvent Subsidiary on Cancellation of Debt in Liquidation 4. Section 332 Does Not Protect Parent from Gain or Loss b. Consequences of Subsidiary's Ownership of Parent Debt if § 332 Does Not Apply a.

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