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1 sty 2017 · A taxpayer that treats a split-off transaction as a tax-free D reorganization must be able to prove to the IRS that the transaction meets all requirements.
Section 318 (a) (5) (B) provides that stock constructively owned by an individual by reason of ownership by a member of his family shall not be considered as owned by him for purposes of making another family member the constructive owner of such stock under section 318 (a) (1).
3 paź 2022 · Treasury and the IRS should clearly address the coordination of section 959(c) with section 316 through a discussion of which interpretations are rejected, how the interpretation that is...
Read Internal Revenue Code Section 316—Dividend defined. Learn about ordinary vs qualified dividends from the IRS and more under IRC Sec. 316 on Tax Notes.
sidered a dividend under section 316. For examples of distributions treated otherwise, see sections 116, 301(c)(2), ... Examples. The application of this section (except paragraph (n)) may be illustrated by the following examples: ... VerDate Mar<15>2010 09:46 May 18, 2012 Jkt 226089 PO 00000 Frm 00020 Fmt 8010 Sfmt 8010 Q:\26\26V4.TXT ofr150 ...
28 lut 2015 · The amendments made by subsections (f) and (g) [amending this section and sections 331, 333, 551, and 562 of this title] shall apply to distributions made in any taxable year of the distributing corporation beginning after December 31, 1963.
The portion of each such distribution which is not regarded as out of earnings and profits of the taxable year shall be considered a taxable dividend to the extent of the earnings and profits accumulated since February 28, 1913, and available on the date of the distribution.
