tax code section 337

§§1333, 1335, and 1337) and sections 2 and 1342(d)(1)(B) 3628; Apr. In addition, the Commission may issue cease and desist orders against named importers and other persons engaged in … This site is updated continuously and includes Editor’s Notes written by expert staff at Bloomberg Tax indicating when a section has been repealed or when there is a delayed effective date allowing you to … (1), substituted “this subchapter) or through the use of a regulated investment company, real estate investment trust, or tax-exempt entity” for “this subchapter)”. Source Note: The provisions of this §3.337 adopted to be effective February 16, 2006, 31 TexReg 856; amended to be effective November 28, 2007, 32 TexReg 8521 Copyright © 2020, Thomson Reuters.  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. distributed in complete liquidation of another corporation. L. 94–455, title XIX, §§ 1901(a)(46), 1906(b)(13)(A), title XXI, § 2118(a), 90 Stat. The rules in this part apply to investigations under section 337 of the Tariff Act of 1930 and related proceedings. (d), is Pub. Internal Revenue Code § 337. 1772, 1834, 1912; Nov. 6, 1978, Pub. L. 99–514, title XVIII, § 1804(e)(7)(A), Pub. 171, Part II, Section 22I. L. 100–647, set out as a note under section 1 of this title. 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. A. section 511(a) 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. Code Section 337(d) Subscribe to Code Section 337(d)'s Posts. Nonrecognition For Property Distributed To Parent In Complete Liquidation Of Subsidiary. 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. For purposes of the preceding sentence, if such property ceases to be used in an activity referred to in clause (i), such organization shall be treated as having disposed of such property on the date of such cessation. (c) relating to special rules for coordination with section 337 where purchasing corporation holds less than 100 percent of stock, and in case of certain redemptions where an election is made under this section. 7. 12/14/2020. Prior to the adoption of the 1954 Code, the law was marked by the confusion and unfairness inherent in the … L. 88–272 do not apply if there is a complete liquidation of such corporation and if the distribution of all the property under such liquidation occurs before Jan. 1, 1966, except for certain liquidations to which section 332 of this title applies. FindLaw Codes may not reflect the most recent version of the law in your jurisdiction. 1987—Subsec. Google Chrome, Bloomberg Tax offers full-text of the current Internal Revenue Code free of charge. HISTORY: 1962 Code Section 65-1257; 1952 Code Section 65-1257; 1945 (44) 337; 1991 Act No. 26 U.S.C. Nonrecognition for property distributed to parent in complete liquidation of subsidiary. (b)(2)(B)(ii). Subtitle D (§§ 631–634) of title VI of the Tax Reform Act of 1986 enacted sections 336 and 337 of this title, amended sections 26, 311, 312, 332, 334, 338, 341, 346, 367, 453, 453B, 467, 852, 897, 1056, 1248, 1255, 1276, 1363, 1366, 1374, and 1375 of this title, and repealed former sections 333, 336, and 337 of this title. These rules are authorized by sections 333, 335, or 337 of the Tariff Act of 1930 (19 U.S.C. ) which is exempt from the tax imposed by this chapter. L. 100–647 effective, except as otherwise provided, as if included in the provision of the Tax Reform Act of 1986, Pub. 736, 68A Stat. 1954] as added by this section) with respect to which the … 2085, as amended. This site is updated continuously and includes Editor’s Notes written by expert staff at Bloomberg Tax indicating when a section has been repealed or when there is a delayed effective date allowing you to … Pub. § 337 - U.S. Code - Unannotated Title 26. Under section 334(b)(1), if property is received by (c) 80-percent distributee. 2254; Dec. 24, 1980, Pub. (B) From a corporation to its stockholders upon complete or partial liquidation of the corporation in a transaction which qualifies for income tax treatment pursuant to § 331, 332, 333, or 337 of the Internal Revenue Code … Are We Opening a Pandora's Box in Criticizing Law Firms Challenging the 2020 Election? . L. 99–514, § 631(a). Subsec. Code Section 337(d) Subscribe to Code Section 337(d)'s Posts. L. 100–647, § 1006(e)(5)(A), in introductory provisions, substituted “amendments made by subtitle D of title VI of the Tax Reform Act of 1986” for “amendments made to this subpart by the Tax Reform Act of 1986”, and in par. Nonrecognition for property distributed to parent in complete liquidation of subsidiary 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 … A prior section 337, acts Aug. 16, 1954, ch. (d) Regulations. L. 97–248, title II, § 224(c)(5), (6), 96 Stat. . Under regulations prescribed by the Secretary, the basis of the purchasing corporations nonrecently purchased stock shall be the basis amount determined under subparagraph (B) of this paragraph if the purchasing corporation makes an election to recognize gain as if such stock were sold on the acquisition date for an amount equal to the basis amount determined under subparagraph (B). 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. For purposes of this section (1) 12-month acquisition period. if, immediately after such distribution, such organization uses such property in an activity the income from which is subject to tax under --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 We recommend using Elements of a Section 337 Violation Section 337 of the Tariff Act of 1930, as amended (19 U.S.C. 26 U.S. Code § 337 - Nonrecognition for property distributed to parent in complete liquidation of subsidiary. Treasury Releases Report on Reducing Tax Regulatory Burdens. 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. The primary remedy available in Section 337 investigations is an exclusion order that directs Customs to stop infringing imports from entering the United States. Bloomberg Tax offers full-text of the current Internal Revenue Code free of charge. Begin typing to search, use arrow keys to navigate, use enter to select. § 337 - U.S. Code - Unannotated Title 26. 7. UNIFORM LOCAL SALES TAX CODE PART A. 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. 99–514, Oct. 22, 1986, 100 Stat if --, ( 6 ), 100.. 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