';


Title 26 Part 1

Title 26 → Chapter I → Subchapter A → Part 1

Electronic Code of Federal Regulations e-CFR

Title 26 Part 1

Title 26Chapter ISubchapter APart 1


TITLE 26—Internal Revenue

CHAPTER I—INTERNAL REVENUE SERVICE, DEPARTMENT OF THE TREASURY (CONTINUED)

SUBCHAPTER A—INCOME TAX (CONTINUED)

PART 1—INCOME TAXES (CONTINUED)

rule

CORPORATE DISTRIBUTIONS AND ADJUSTMENTS

Effects on Recipients

§1.301-1
Rules applicable with respect to distributions of money and other property.
§1.302-1
General.
§1.302-2
Redemptions not taxable as dividends.
§1.302-3
Substantially disproportionate redemption.
§1.302-4
Termination of shareholder's interest.
§1.303-1
General.
§1.303-2
Requirements.
§1.303-3
Application of other sections.
§1.304-1
General.
§1.304-2
Acquisition by related corporation (other than subsidiary).
§1.304-3
Acquisition by a subsidiary.
§1.304-4
Special rules for the use of related corporations to avoid the application of section 304.
§1.304-5
Control.
§1.304-6
Amount constituting a dividend. [Reserved]
§1.304-7
Certain acquisitions by foreign acquiring corporations.
§1.305-1
Stock dividends.
§1.305-2
Distributions in lieu of money.
§1.305-3
Disproportionate distributions.
§1.305-4
Distributions of common and preferred stock.
§1.305-5
Distributions on preferred stock.
§1.305-6
Distributions of convertible preferred.
§1.305-7
Certain transactions treated as distributions.
§1.305-8
Effective dates.
§1.306-1
General.
§1.306-2
Exception.
§1.306-3
Section 306 stock defined.
§1.306-4
Effective/applicability date.
§1.307-1
General.
§1.307-2
Exception.

effects on corporation

§1.312-1
Adjustment to earnings and profits reflecting distributions by corporations.
§1.312-2
Distribution of inventory assets.
§1.312-3
Liabilities.
§1.312-4
Examples of adjustments provided in section 312(c).
§1.312-5
Special rule for partial liquidations and certain redemptions.
§1.312-6
Earnings and profits.
§1.312-7
Effect on earnings and profits of gain or loss realized after February 28, 1913.
§1.312-8
Effect on earnings and profits of receipt of tax-free distributions requiring adjustment or allocation of basis of stock.
§1.312-9
Adjustments to earnings and profits reflecting increase in value accrued before March 1, 1913.
§1.312-10
Allocation of earnings in certain corporate separations.
§1.312-11
Effect on earnings and profits of certain other tax-free exchanges, tax-free distributions, and tax-free transfers from one corporation to another.
§1.312-12
Distributions of proceeds of loans guaranteed by the United States.
§1.312-15
Effect of depreciation on earnings and profits.

definitions; constructive ownership of stock

§1.316-1
Dividends.
§1.316-2
Sources of distribution in general.
§1.317-1
Property defined.
§1.318-1
Constructive ownership of stock; introduction.
§1.318-2
Application of general rules.
§1.318-3
Estates, trusts, and options.
§1.318-4
Constructive ownership as actual ownership; exceptions.

Corporate Liquidations

effects on recipients

§1.331-1
Corporate liquidations.
§1.332-1
Distributions in liquidation of subsidiary corporation; general.
§1.332-2
Requirements for nonrecognition of gain or loss.
§1.332-3
Liquidations completed within one taxable year.
§1.332-4
Liquidations covering more than one taxable year.
§1.332-5
Distributions in liquidation as affecting minority interests.
§1.332-6
Records to be kept and information to be filed with return.
§1.332-7
Indebtedness of subsidiary to parent.
§1.334-1
Basis of property received in liquidations.
§1.336-0
Table of contents.
§1.336-1
General principles, nomenclature, and definitions for a section 336(e) election.
§1.336-2
Availability, mechanics, and consequences of section 336(e) election.
§1.336-3
Aggregate deemed asset disposition price; various aspects of taxation of the deemed asset disposition.
§1.336-4
Adjusted grossed-up basis.
1.336-5
1.336-5   Effective/applicability dates.

effects on corporation

§1.337-1
Nonrecognition for property distributed to parent in complete liquidation of subsidiary.
§1.337(d)-1
Transitional loss limitation rule.
§1.337(d)-1T
[Reserved]
§1.337(d)-2
Loss limitation rules.
§1.337(d)-3
Gain recognition upon certain partnership transactions involving a partner's stock.
§1.337(d)-4
Taxable to tax-exempt.
§1.337(d)-5
Old transitional rules imposing tax on property owned by a C corporation that becomes property of a RIC or REIT
§1.337(d)-6
New transitional rules imposing tax on property owned by a C corporation that becomes property of a RIC or REIT.
§1.337(d)-7
Tax on property owned by a C corporation that becomes property of a RIC or REIT.
§1.338-0
Outline of topics.
§1.338-1
General principles; status of old target and new target.
§1.338-2
Nomenclature and definitions; mechanics of the section 338 election.
§1.338-3
Qualification for the section 338 election.
§1.338-4
Aggregate deemed sale price; various aspects of taxation of the deemed asset sale.
§1.338-5
Adjusted grossed-up basis.
§1.338-6
Allocation of ADSP and AGUB among target assets.
§1.338-7
Allocation of redetermined ADSP and AGUB among target assets.
§1.338-8
Asset and stock consistency.
§1.338-9
International aspects of section 338.
§1.338-10
Filing of returns.
§1.338-11
Effect of section 338 election on insurance company targets.
§1.338(h)(10)-1
Deemed asset sale and liquidation.
§1.338(i)-1
Effective/applicability date.

definition

§1.346-1
Partial liquidation.
§1.346-2
Treatment of certain redemptions.
§1.346-3
Effect of certain sales.

Corporate Organizations and Reorganizations

corporate organizations

§1.351-1
Transfer to corporation controlled by transferor.
§1.351-2
Receipt of property.
§1.351-3
Records to be kept and information to be filed.

effects on shareholders and security holders

§1.354-1
Exchanges of stock and securities in certain reorganizations.
§1.355-0
Outline of sections.
§1.355-1
Distribution of stock and securities of a controlled corporation.
§1.355-2
Limitations.
§1.355-3
Active conduct of a trade or business.
§1.355-4
Non pro rata distributions, etc.
§1.355-5
Records to be kept and information to be filed.
§1.355-6
Recognition of gain on certain distributions of stock or securities in controlled corporation.
§1.355-7
Recognition of gain on certain distributions of stock or securities in connection with an acquisition.
§1.355-8T
Definition of predecessor and successor and limitations on gain recognition under section 355(e) and section 355(f) (temporary).
§1.356-1
Receipt of additional consideration in connection with an exchange.
§1.356-2
Receipt of additional consideration not in connection with an exchange.
§1.356-3
Rules for treatment of securities as “other property”.
§1.356-4
Exchanges for section 306 stock.
§1.356-5
Transactions involving gift or compensation.
§1.356-6
Rules for treatment of nonqualified preferred stock as other property.
§1.356-7
Rules for treatment of nonqualified preferred stock and other preferred stock received in certain transactions.
§1.357-1
Assumption of liability.
§1.357-2
Liabilities in excess of basis.
§1.358-1
Basis to distributees.
§1.358-2
Allocation of basis among nonrecognition property.
§1.358-3
Treatment of assumption of liabilities.
§1.358-4
Exceptions.
§1.358-5
Special rules for assumption of liabilities.
§1.358-6
Stock basis in certain triangular reorganizations.
§1.358-7
Transfers by partners and partnerships to corporations.

effects on corporation

§1.361-1
Nonrecognition of gain or loss to corporations.
§1.362-1
Basis to corporations.
§1.362-2
Certain contributions to capital.
§1.362-3
Basis of importation property acquired in loss importation transaction.
§1.362-4
Basis of loss duplication property.
§1.367(a)-0
Table of contents.
§1.367(a)-1
Transfers to foreign corporations subject to section 367(a): In general.
§1.367(a)-1T
Transfers to foreign corporations subject to section 367(a): In general (temporary).
§1.367(a)-2
Exceptions for transfers of property for use in the active conduct of a trade or business.
§1.367(a)-3
Treatment of transfers of stock or securities to foreign corporations.
§1.367(a)-4
Special rule applicable to U.S. depreciated property.
§1.367(a)-5
[Reserved]
§1.367(a)-6
Transfer of foreign branch with previously deducted losses.
§1.367(a)-6T
Transfer of foreign branch with previously deducted losses (temporary).
§1.367(a)-7
Outbound transfers of property described in section 361(a) or (b).
§1.367(a)-8
Gain recognition agreement requirements.
§1.367(a)-9T
Treatment of deemed section 351 exchanges pursuant to section 304(a)(1) (temporary).
§1.367(b)-0
Table of contents.
§1.367(b)-1
Other transfers.
§1.367(b)-2
Definitions and special rules.
§1.367(b)-3
Repatriation of foreign corporate assets in certain nonrecognition transactions.
§1.367(b)-3T
Repatriation of foreign corporate assets in certain nonrecognition transactions (temporary).
§1.367(b)-4
Acquisition of foreign corporate stock or assets by a foreign corporation in certain nonrecognition transactions.
§1.367(b)-5
Distributions of stock described in section 355.
§1.367(b)-6
Effective/applicability dates and coordination rules.
§1.367(b)-7
Carryover of earnings and profits and foreign income taxes in certain foreign-to-foreign nonrecognition transactions.
§1.367(b)-8
Allocation of earnings and profits and foreign income taxes in certain foreign corporate separations. [Reserved]
§1.367(b)-9
Special rule for F reorganizations and similar transactions.
§1.367(b)-10
Acquisition of parent stock or securities for property in triangular reorganizations.
§1.367(b)-12
Subsequent treatment of amounts attributed or included in income.
§1.367(b)-13
Special rules for determining basis and holding period.
§1.367(d)-1
Transfers of intangible property to foreign corporations.
§1.367(d)-1T
Transfers of intangible property to foreign corporations (temporary).
§1.367(e)-0
Outline of §§1.367(e)-1 and 1.367(e)-2.
§1.367(e)-1
Distributions described in section 367(e)(1).
§1.367(e)-2
Distributions described in section 367(e)(2).

special rule; definitions

§1.368-1
Purpose and scope of exception of reorganization exchanges.
§1.368-2
Definition of terms.
§1.368-3
Records to be kept and information to be filed with returns.

Insolvency Reorganizations

Carryovers

§1.381(a)-1
General rule relating to carryovers in certain corporate acquisitions.
§1.381(b)-1
Operating rules applicable to carryovers in certain corporate acquisitions.
§1.381(c)(1)-1
Net operating loss carryovers in certain corporate acquisitions.
§1.381(c)(1)-2
Net operating loss carryovers; two or more dates of distribution or transfer in the taxable year.
§1.381(c)(2)-1
Earnings and profits.
§1.381(c)(3)-1
Capital loss carryovers.
§1.381(c)(4)-1
Method of accounting.
§1.381(c)(5)-1
Inventory method.
§1.381(c)(6)-1
Depreciation method.
§1.381(c)(8)-1
Installment method.
§1.381(c)(9)-1
Amortization of bond discount or premium.
§1.381(c)(10)-1
Deferred exploration and development expenditures.
§1.381(c)(11)-1
Contributions to pension plan, employees' annuity plans, and stock bonus and profit-sharing plans.
§1.381(c)(12)-1
Recovery of bad debts, prior taxes, or delinquency amounts.
§1.381(c)(13)-1
Involuntary conversions.
§1.381(c)(14)-1
Dividend carryover to personal holding company.
§1.381(c)(15)-1
Indebtedness of certain personal holding companies.
§1.381(c)(16)-1
Obligations of distributor or transferor corporation.
§1.381(c)(17)-1
Deficiency dividend of personal holding company.
§1.381(c)(18)-1
Depletion on extraction of ores or minerals from the waste or residue of prior mining.
§1.381(c)(19)-1
Charitable contribution carryovers in certain acquisitions.
§1.381(c)(21)-1
Pre-1954 adjustments resulting from change in method of accounting.
§1.381(c)(22)-1
Successor life insurance company.
§1.381(c)(23)-1
Investment credit carryovers in certain corporate acquisitions.
§1.381(c)(24)-1
Work incentive program credit carryovers in certain corporate acquisitions.
§1.381(c)(25)-1
Deficiency dividend of a qualified investment entity.
§1.381(c)(26)-1
Credit for employment of certain new employees.
§1.381(d)-1
Operations loss carryovers of life insurance companies.
§1.382-1
Table of contents.
§1.382-1T
Table of contents (temporary).
§1.382-2
General rules for ownership change.
§1.382-2T
Definition of ownership change under section 382, as amended by the Tax Reform Act of 1986 (temporary).
§1.382-3
Definitions and rules relating to a 5-percent shareholder.
§1.382-4
Constructive ownership of stock.
§1.382-5
Section 382 limitation.
§1.382-6
Allocation of income and loss to periods before and after the change date for purposes of section 382.
§1.382-7
Built-in gains and losses.
§1.382-8
Controlled groups.
§1.382-9
Special rules under section 382 for corporations under the jurisdiction of a court in a title 11 or similar case.
§1.382-10
Special rules for determining time and manner of acquisition of an interest in a loss corporation.
§1.382-11
Reporting requirements.
§1.382-12
Determination of adjusted Federal long-term rate.
§1.383-0
Effective date.
§1.383-1
Special limitations on certain capital losses and excess credits.
§1.383-2
Limitations on certain capital losses and excess credits in computing alternative minimum tax. [Reserved]
§1.385-1
General provisions.
§1.385-2
Treatment of certain interests between members of an expanded group.
§1.385-3
Transactions in which debt proceeds are distributed or that have a similar effect.
§1.385-3T
Certain distributions of debt instruments and similar transactions (temporary).
§1.385-4T
Treatment of consolidated groups.
§§1.386-1.400
[Reserved]

© e-CFR 2019

FR | USC | CFR | eCFR