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Exclusion of Stock which Is Limited and Preferred as to Dividends 4. Procedural Requirements for a Three-Year Liquidation a. Failure to File Waiver Not a Forfeiture of § 332 c. Section 269(b): Liquidation of Recently Purchased Subsidiary 5. Section 382: Limitation on Loss Carryovers and Built-In Losses 4. Deduction of Organizational, Liquidation, and Dissolution Expenses 1. Distribution Solely of Cash Qualifies as â€œPropertyâ€ E. Subsidiary Liquidations Not Qualifying Under § 332 A.
The Portfolio also discusses the relationship between the liquidation rules and §338 (the election to treat a stock purchase as a purchase of assets).
Application of Collapsible Corporation Rules to Minority Shareholders 5. Tax Consequences to Liquidating Subsidiary of Distributions to Minority Shareholders 1.
Prior Ownership of Target Stock by Acquirer - Elimination of the â€œBausch & Lombâ€ Rule 4.
Assignment of Income Doctrine and the Tax Benefit Rule 2.
Assignment of Income, Reserve for Bad Debts, Recapture, and Installment Obligations 1.