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A distribution to which section 355 applies (or so much of section 356 as relates to section 355) is not a distribution in partial liquidation within the meaning of section 346(a).

A distribution which occurs within the taxable year in which the plan is adopted or within the succeeding taxable year and which meets the requirements of subsection (b) of section 346 falls within paragraph (a)(2) of this section and within section 346(a)(2). 2657]§ 108 - Income from discharge of indebtedness§ 110 - Qualified lessee construction allowances for short-term leases§ 129 - Dependent care assistance programs§ 132 - Certain fringe benefits§ 148 - Arbitrage§ 149 - Bonds must be registered to be tax exempt; other requirements§ 150 - Definitions and special rules§ 152 - Dependent defined§ 162 - Trade or business expenses§ 163 - Interest§ 165 - Losses§ 166 - Bad debts§ 168 - Accelerated cost recovery system§ 170 - Charitable, etc., contributions and gifts§ 171 - Amortizable bond premium§ 179 - Election to expense certain depreciable business assets§ 179A - Repealed.

In general, a distribution which will qualify under section 346(b) may consist of, but is not limited to: Assets (other than inventory or property described in subdivision (ii) of this subparagraph) used in the trade or business throughout the five-year period immediately before the distribution (for this purpose an asset shall be considered used in the trade or business during the period of time the asset which it replaced was so used), or The items constituting such inventory or such property were substantially similar to the items constituting such inventory or property during the five-year period immediately before the distribution, and The quantity of such items on the date of distribution was not substantially in excess of the quantity of similar items regularly on hand in the conduct of such business during such five-year period, or Proceeds from the sale of inventory or property described in subdivision (iii) of this subparagraph, if such inventory or property is sold in bulk in the course of termination of such trade or business and if with respect to such inventory the conditions of subdivision (iii)( In the case of a business the proceeds of the sale of the assets of which are distributed, such business was actively conducted until the date of sale and the proceeds of such sale were distributed as soon thereafter as reasonably possible. 4037]§ 36B - Refundable credit for coverage under a qualified health plan§ 38 - General business credit§ 40 - Alcohol, etc., used as fuel§ 41 - Credit for increasing research activities§ 42 - Low-income housing credit§ 43 - Enhanced oil recovery credit§ 45D - New markets tax credit§ 46 - Amount of credit§ 47 - Rehabilitation credit§ 52 - Special rules§ 56 - Adjustments in computing alternative minimum taxable income§ 58 - Denial of certain losses§ 61 - Gross income defined§ 62 - Adjusted gross income defined§ 66 - Treatment of community income§ 67 - 2-percent floor on miscellaneous itemized deductions§ 72 - Annuities; certain proceeds of endowment and life insurance contracts§ 101 - Certain death benefits§ 103 - Interest on State and local bonds§ 103A - Repealed.

This is a list of United States Code sections, Statutes at Large, Public Laws, and Presidential Documents, which provide rulemaking authority for this CFR Part.

Distinguishing Ordinary Partnership Income and Special Allocations B. Character of Income or Loss to Partnership Entity D.

It is not guaranteed to be accurate or up-to-date, though we do refresh the database weekly. A distribution is treated as in partial liquidation of a corporation if: An example of a distribution which will qualify as a partial liquidation under subparagraph (2) of this paragraph and section 346(a) is a distribution resulting from a genuine contraction of the corporate business such as the distribution of unused insurance proceeds recovered as a result of a fire which destroyed part of the business causing a cessation of a part of its activities. On the other hand, the distribution of funds attributable to a reserve for an expansion program which has been abandoned does not qualify as a partial liquidation within the meaning of section 346(a). Sometimes companies that you own make distributions that are eligible for special tax treatment and do not have to be reported as regular dividend income.This is a different type of distribution from regular return of capital payments that come from dividends paid in excess of accumulated earnings and profits of the corporation.




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