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Posted by / 04-Apr-2020 20:05

Liquidating distribution two years

For purposes of clauses (ii) and (iii), the term “securities” includes obligations of State and local governments, commodity futures contracts, shares of regulated investment companies and real estate investment trusts, and other investments constituting a security within the meaning of the Investment Company Act of 1940 (15 U. For purposes of the preceding sentence, if the acquired corporation is liquidated pursuant to the plan of reorganization, any distribution to its creditors in connection with such liquidation shall be treated as pursuant to the plan of reorganization. in the case of a transaction with respect to which the requirements of subparagraphs (A) and (B) of section 354(b)(1) are met, the term “control” has the meaning given such term by section 304(c), and in the case of a transaction with respect to which the requirements of section 355 (or so much of section 356 as relates to section 355) are met, the fact that the shareholders of the distributing corporation dispose of part or all of the distributed stock, or the fact that the corporation whose stock was distributed issues additional stock, shall not be taken into account. 98–369, § 64(a), designated existing provisions as par.

For purposes of this subparagraph, in determining total assets there shall be excluded cash and cash items (including receivables). (ii) read as follows: “in the case of a transaction with respect to which the requirements of section 355 are met, the shareholders described in paragraph (1)(D) shall be treated as having control of the corporation to which the assets are transferred if such shareholders own (immediately after the distribution) stock possessing— “(I) more than 50 percent of the total combined voting power of all classes of stock of such corporation entitled to vote, and “(II) more than 50 percent of the total value of shares of all classes of stock of such corporation.” 1997—Subsec.

(2) defining term “control” as having meaning given to such term by section 304(c) in case of any transaction with respect to which requirements of subpars.

(viii) which provided that in applying paragraph (3) of section 267(b) in respect of any transaction to which this subparagraph applies, the reference to a personal holding company in such paragraph (3) be treated as including a reference to an investment company and the determination of whether a corporation is an investment company be made as of the time immediately before the transaction instead of with respect to the taxable year referred to in such paragraph (3).

(D), as in effect before the amendment made by section 904(a) of Pub.

99–514, § 1804(h)(3), inserted “(other than for purposes of subparagraph (C))” after “subchapter”.

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In the case of a reorganization qualifying under paragraph (1)(A) or (1)(G) of subsection (a) by reason of paragraph (2)(D) of that subsection, the term “a party to a reorganization” includes the controlling corporation referred to in such paragraph (2)(D).