Finally, the Portfolio reviews the issues arising from the liquidation of insolvent subsidiaries and the existence of intercorporate debt in subsidiary liquidations.
Assignment of Income Doctrine and the Tax Benefit Rule 2.
Assignment of Income, Reserve for Bad Debts, Recapture, and Installment Obligations 1.
Liquidating Distribution to Preferred But Not to Common Stock - Spaulding Bakeries, Inc. Subsidiary Not Taxable if § 332 Applies to the Liquidation b.
Tax Consequences to Parent on Liquidation of Insolvent Subsidiary a. Qualification of an Insolvent Subsidiary for a Nontaxable Liquidation D. Determining Whether a Taxable Liquidation Is Advantageous 2. Consequences Before Liquidation if Parent Acquires Debt from Unrelated Party c. Consequences to Subsidiary of Repayment of Debt to Parent a.
Treatment Upon Liquidation of Subsidiary of Parent's Previously Capitalized Cost of Acquiring Subsidiary 6. Inclusion of Transitory Subsidiary in Consolidated Return 4.
Qualification of an S Corporation as a Corporate Parent in a § 332 Liquidation 1. The Portfolio also discusses the tax treatment of liquidations before the repeal of that doctrine. To view this Portfolio, take a free trial to Bloomberg BNA Tax & Accounting BLOOMBERG BNA TAX & ACCOUNTING This Portfolio is available with a subscription to Bloomberg BNA Tax & Accounting, a comprehensive research solution including over 500 Tax Management Portfolios, practice tools, primary sources and timely news. Nontaxable Liquidation of Subsidiary if § 338 Election Is Made 1. Miscellaneous Considerations in a Subsidiary Liquidation A. Section 384: Limitations on Use of Built-In Gains of Acquired Subsidiary 6. The Portfolio identifies issues arising in the context of deemed liquidations, and the special problems that can occur as a result of the interplay of the liquidation provisions with the S corporation rules and the consolidated return regulations.