9.7 - Corporate Tax Special Topics - Subsidiary Liquidation Flashcards
Subsidiary Liquidation - Nonrecognition
True or False >>> both, the parent corporation and the controlled subsidiary recognized gains and losses on a liquidating distribution to the parent.
False – neither the parent corporation nor a controlled subsidiary recognizes gain or loss on a liquidating distribution to the parent
Subsidiary Liquidation - Control
What does control mean?
The parent owns 80% or more of both the voting power and total value of the stock of the liquidating corporation
Subsidiary Liquidation - Basis
How is basis in property distributed when the property is transferred to the parent?
The basis is distributed to the parent and basis in stock in the subsidiary disappears
Subsidiary Liquidation - Liabilities
How are gains recognized on distributions that satisfy obligations of the subsidiary to the parent?
Gains are not recognized
Do tax attributes of the subsidiary, such as NOLs and capital losses, carryover to the parent?
Yes