RS 47:337.96 — Uniform local sales tax administrative code and louisiana register; publication; index RS 47:337.97 — Judicial review of validity or applicability of rules RS 47:337.98 — Appeals A prior section 337, acts Aug. 16, 1954, ch. 26 U.S.C. Begin typing to search, use arrow keys to navigate, use enter to select. Prior to the adoption of the 1954 Code, the law was marked by the confusion and unfairness inherent in the decisions of No gain or loss shall be recognized to the liquidating corporation on the distribution to the 80-percent distributee of any property in a complete liquidation to which section 332 applies. Pub. If any property distributed in the liquidation is subject to a liability or the shareholder assumes a liability of the liquidating corporation in connection with the distribution, for purposes of subsection (a) and section 337, the fair market value of such property shall be treated as not less than the amount of such liability. McDermott’s Real-Time Tax Disputes Insights. L. 100–647 effective, except as otherwise provided, as if included in the provision of the Tax Reform Act of 1986, Pub. I.R.C. 12/14/2020. 7. SECTION 12-33-60. For purposes of this section (1) 12-month acquisition period. Except as provided in subparagraph (B), paragraph (1) and subsection (a) shall not apply where the 80-percent distributee is an organization (other than a cooperative described in section 521) which is exempt from the tax imposed by this chapter. the board of directors of a party to the reorganization adopted a resolution to solicit shareholder approval for the transaction, or, the shareholders or the board of directors of a party to the reorganization approved the transaction.”, {'misc': '', 'cleanpath': '/uscode/text/26/337', 'headtext': ' Nonrecognition for property distributed to parent in complete liquidation of subsidiary', 'cfr_titles': [{'title': '26', 'parts': [{'part': '1', 'cleanpath': '/cfr/text/26/part-1', 'headtext': 'INCOME TAXES'}]}], 'section': '337'}. § 337 - U.S. Code - Unannotated Title 26. §§1333, 1335, and 1337) and sections 2 and 1342(d)(1)(B) Exemption from tax of certain property from outside continental limits of United States. L. 100–647, set out as a note under section 1 of this title.  For purposes of this section, the determination of whether any corporation is an 80-percent distributee shall be made without regard to any consolidated return regulation. U.S. GAAP Codification, U.S. Tax Code by Section: Financial Accounting, Intermediate Accounting, Advanced Accounting: IFRS-U.S. GAAP Comparison, Securities Law Library: USC Title 26 enacted through 2008 § 337. The amendments made by this section [enacting this section and amending sections 168, 318, 334, 336, 337, 381, and 617 of this title] shall apply to any target corporation (within the meaning of section 338 of the Internal Revenue Code of 1986 [formerly I.R.C. 1615; Oct. 4, 1976, Pub. Internet Explorer 11 is no longer supported. For complete classification of this Act to the Code, see Tables. U.S. GAAP Codification, U.S. Tax Code by Section: Financial Accounting, Intermediate Accounting, Advanced Accounting: IFRS-U.S. GAAP Comparison, Securities Law Library: USC Title 26 enacted through 2008 § 337. For more detailed codes research information, including annotations and citations, please visit Westlaw. (c). HISTORY: 1962 Code Section 65-1257; 1952 Code Section 65-1257; 1945 (44) 337; 1991 Act No. Section 1237 Capital Gain Opportunity: This is a specific tax credit that allows taxpayers to receive capital gains treatment on the sale of subdivided lots of land. . Internal Revenue Code Section 338(h)(10) Certain stock purchases treated as asset acquisitions. section 336 Pub. Elements of a Section 337 Violation Section 337 of the Tariff Act of 1930, as amended (19 U.S.C. 7. Exception where property will be used in unrelated business, The Secretary shall prescribe such regulations as may be necessary or appropriate to carry out the purposes of the amendments made by subtitle D of title VI of the, “The amendment made by subparagraph (A)(ii) [amending this section] shall not apply to any reorganization if before, Subchapter C. Corporate Distributions and Adjustments, Pub. 489; Oct. 22, 1986, Pub. LIQUIDATIONS UNDER SECTION 337 Theodore M. Garver The Internal Revenue Code of 1954 included a new provision, section 337, which allows the tax-free sale of property by a corporation in the process of liquidation. 1337), provides that unfair methods of competition and unfair acts in the importation of articles into the United States, or in their sale for importation, or sale within the United States after importation, are unlawful.  regulations providing for appropriate coordination of the provisions of this section with the provisions of this title relating to taxation of foreign corporations and their shareholders. Prior to amendment, text read as follows: “If property is received by a corporate distributee in a distribution in a complete liquidation to which section 332 applies (or in a transfer described in section 337(b)(1)), the basis of such property in the hands of such distributee shall be the same as it would be in the hands of the transferor; except that, in any case in which gain or loss is recognized by the liquidating corporation with respect to such property, the basis of such … 337. L. 99–514, to which such amendment relates, see section 1019(a) of Pub. (1) Indebtedness of subsidiary to parent. . section 332 (ii) Later disposition or change in use. . , any transfer of property to the 80-percent distributee in satisfaction of such indebtedness shall be treated as a distribution to such distributee in such liquidation. L. 100–647, § 1006(e)(4)(A), (B), substituted “described in section 511(a)(2)” for “described in section 511(a)(2) or 511(b)(2)” and “in an activity the income from which is subject to tax under section 511(a)” for “in an unrelated trade or business (as defined in section 513)”. 2904; Nov. 10, 1978, Pub. If the Board of Tax Appeals, pursuant to a hearing of an appeal from an assessment of the collector in accordance with the provisions of R.S. (1) In general If property is received by a corporate distributee in a distribution in a complete liquidation to which section 332 applies (or in a transfer described in section 337(b)(1)), the basis of such property in the hands of such distributee shall be the same as it would be in the hands of the transferor; except that, in the hands … Board of Tax Appeals' finding of overpayment upon appeal from assessment. (d) Regulations. ) which is exempt from the tax imposed by this chapter. Code Section 337(d) Subscribe to Code Section 337(d)'s Posts. Amendment by Pub. 1988—Subsec. L. 96–589, § 5(c), 94 Stat. FEDERAL INCOME TAX: INVOLUNTARY CONVERSIONS AS SECTION 337 SALES OR EXCHANGES THE 1954 Internal Revenue Code contains an important innovation in section 337(a), which relates to taxation of gains and losses on the sale and exchange of … L. 100–203, set out as a note under section 304 of this title. --The Secretary shall prescribe such regulations as may be necessary or appropriate to carry out the purposes of the amendments made by subtitle D of title VI of the Tax Reform Act of 1986, including--, (1) 2085, as amended. regulations providing for appropriate coordination of the provisions of this section with the provisions of this title relating to taxation of foreign corporations and their shareholders. section 511(a) Nonrecognition for property distributed to parent in … For purposes of the preceding sentence, an election under section 338(g) of the Internal Revenue Code of 1986 (or an election under section 338(h)(10) of such Code qualifying as a section 337 liquidation pursuant to regulations prescribed by the Secretary under section 1.338(h)(10)-1T(j)) made in connection with a sale or … Nonrecognition for property distributed to parent in complete liquidation of subsidiary on Westlaw, industry-leading online legal research system, Amazon Alleged to Spy on Its Workers Even More Than Its Consumers, Betting Money Is Now on Supreme Court Keeping ACA Largely Intact. 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