Code Sections-MC2- Stock redemptions Flashcards
301
distribution of property- applies if 302 is inapplcable
302 (a)
distributions in redemption of stock
exchange (sale) treatment
302 (b)
distributions in redemption of stock redemptions treated as exchanges (1) not essentially equivalent to a dividend (2) substantially disproportionate (3) complete termination (4) partial liquidation
302(c)
distributions in redemption of stock
constructive ownership
(1) reference to 318
(2) waiver of family attribution
302 (d)
distributions in redemption of stock
redemption treated as distribution under 301 if 302(a) is inapplicable because no 302(b) condition is satisfied
302(e)
distributions in redemption of stock
partial liquidation defined
303
redemption to pay death taxes
304
redemption through related corporations
311
taxability to distributing corporation
(a) no loss recognized on the distribution of cash or depreciation (in value) of property
(b) gain recognized on the distribution of appreciated (in value) property
312 (a)
effect on earnings and profits
reduction of E&P for 301 distributions
312 (b)
effect on earnings and profits
301 distributions of appreciated property
312 (n)(7)
effect on earnings and profits
adjustment of E&P for redemptions
316(a)
dividend defined,
(a) GR: applies if 302(a) is inapplicable
317(a)
317(b)
other definitions
(a) Property
(b) redemption: acquisition of corporations own stock from a shareholder in exchange for property
318
constructive ownership of stock