Chapter 4 corporate nonliquidating distributions parent dating rules
(A) to (D) which provided what the amount of any distribution would be for noncorporate distributees, corporate distributees, certain corporate distributees of foreign corporations, and foreign corporate distributees.(1) to (4) which provided what the basis of property received would be for noncorporate distributees, corporate distributees, foreign corporate distributees, and certain corporate distributees of foreign corporations.
These attribution rules provide that shares owned by a shareholder’s parents, children, and grandchildren (but not siblings) are considered to be owned by the shareholder. Similarly, shares held by corporations, trusts, and partnerships are deemed to be owned by their shareholders beneficiaries, and partners, and vice versa. As a result, shares held by these family members and entities are considered to be owned by the shareholder for purposes of determining whether the distribution qualifies as a redemption.
Pace also serves as the Director of both the Master of Accounting program and the Master of Taxation program at Weber State. Pace was a full-time tax attorneyat large law firms in Arizona and Utah. Pace graduated from New York University with a Masterof Laws degree in taxation after receiving his Juris Doctor with honors from Washburn University School of Law.
He also received a Master of Taxation degree from Arizona State University and his Bachelor of Science degree from the University of Utah.
94–455, § 205(c)(1)(B), substituted “1252(a), or 1254(a)” for “or 1252(a)”.
94–455, § 1906(b)(13)(A), struck out “or his delegate” after “Secretary”.
Instead, the distribution is governed by the general nonrecognition rule of Code § 311(a), which prevent the corporation from recognizing loss on a transfer of depreciated property. § 302(b)(1), this test is usually used only when the safe harbors of I.