Corporations address non-liquidating distributions from a retirement
The form breaks total distributions down into taxable and nontaxable categories. The other shareholders feel that the tracts will appreciate at about the same rate, so they are willing to distribute any of the tracts. Copyright Gale, Cengage Learning.
The corporation does not recognize gain or loss when it distributes cash to shareholders or when it redeems stock in exchange for cash payments Sec. The portion of the corporation's gain attributable to recapture items e. At the shareholder level, a nonliquidating corporate distribution can produce a variety of tax consequences, including taxable dividend treatment, capital gain or loss, or a reduction in stock basis.
Instead of distributing the I stock, the corporation should sell it and distribute the resulting sales proceeds to E. Tracts of land owned by J Corp.
However, they want to avoid corporate-level gain. When multiple properties are distributed, the corporation computes gain on an asset-by-asset basis Rev. The corporate-level tax consequences of a nonliquidating corporate distribution depend on whether the distribution consists of cash or property other than cash.
However, the shareholders agree that J can distribute one of the tracts of land to A see the exhibit. At the corporate level, a nonliquidating corporate distribution can also have varying tax consequences. Structuring the redemption in this fashion would not cause any adverse tax effects for E. However, the shareholders have agreed to distribute a parcel of land held for investment purposes and stock in a publicly traded company, I, Inc.
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