CORPORATE DISTRIBUTIONS AND ADJUSTMENTS
EFFECTS ON RECIPIENTS

• § 1.301-1 - Rules applicable with respect to distributions of money and other property.

• § 1.302-1 - General.

• § 1.302-2 - Redemptions not taxable as dividends.

• § 1.302-3 - Substantially disproportionate redemption.

• § 1.302-4 - Termination of shareholder's interest.

• § 1.303-1 - General.

• § 1.303-2 - Requirements.

• § 1.303-3 - Application of other sections.

• § 1.304-1 - General.

• § 1.304-2 - Acquisition by related corporation (other than subsidiary).

• § 1.304-3 - Acquisition by a subsidiary.

• § 1.304-4 -

• § 1.304-5 - Control.

• § 1.304-6 - Amount constituting a dividend. [Reserved]

• § 1.304-7 - Certain acquisitions by foreign acquiring corporations.

• § 1.305-1 - Stock dividends.

• § 1.305-2 - Distributions in lieu of money.

• § 1.305-3 - Disproportionate distributions.

• § 1.305-4 - Distributions of common and preferred stock.

• § 1.305-5 - Distributions on preferred stock.

• § 1.305-6 - Distributions of convertible preferred.

• § 1.305-7 - Certain transactions treated as distributions.

• § 1.305-8 - Effective dates.

• § 1.306-1 - General.

• § 1.306-2 - Exception.

• § 1.306-3 - Section 306 stock defined.

• § 1.306-4 - Effective/applicability date.

• § 1.307-1 - General.

• § 1.307-2 - Exception.

EFFECTS ON CORPORATION

• § 1.312-1 - Adjustment to earnings and profits reflecting distributions by corporations.

• § 1.312-2 - Distribution of inventory assets.

• § 1.312-3 - Liabilities.

• § 1.312-4 - Examples of adjustments provided in section 312(c).

• § 1.312-5 - Special rule for partial liquidations and certain redemptions.

• § 1.312-6 - Earnings and profits.

• § 1.312-7 - Effect on earnings and profits of gain or loss realized after February 28, 1913.

• § 1.312-8 - Effect on earnings and profits of receipt of tax-free distributions requiring adjustment or allocation of basis of stock.

• § 1.312-9 - Adjustments to earnings and profits reflecting increase in value accrued before March 1, 1913.

• § 1.312-10 - Allocation of earnings in certain corporate separations.

• § 1.312-11 - Effect on earnings and profits of certain other tax-free exchanges, tax-free distributions, and tax-free transfers from one corporation to another.

• § 1.312-12 - Distributions of proceeds of loans guaranteed by the United States.

• § 1.312-15 - Effect of depreciation on earnings and profits.

DEFINITIONS; CONSTRUCTIVE OWNERSHIP OF STOCK

• § 1.316-1 - Dividends.

• § 1.316-2 - Sources of distribution in general.

• § 1.317-1 - Property defined.

• § 1.318-1 - Constructive ownership of stock; introduction.

• § 1.318-2 - Application of general rules.

• § 1.318-3 - Estates, trusts, and options.

• § 1.318-4 - Constructive ownership as actual ownership; exceptions.

CORPORATE LIQUIDATIONS
EFFECTS ON RECIPIENTS

• § 1.331-1 - Corporate liquidations.

• § 1.332-1 - Distributions in liquidation of subsidiary corporation; general.

• § 1.332-2 - Requirements for nonrecognition of gain or loss.

• § 1.332-3 - Liquidations completed within one taxable year.

• § 1.332-4 - Liquidations covering more than one taxable year.

• § 1.332-5 - Distributions in liquidation as affecting minority interests.

• § 1.332-6 -

• § 1.332-7 - Indebtedness of subsidiary to parent.

• § 1.332-8 - Recognition of gain on liquidation of certain holding companies.

• § 1.334-1 - Basis of property received in liquidations.

• § 1.336-0 - Table of contents.

• § 1.336-1 - General principles, nomenclature, and definitions for a section 336(e) election.

• § 1.336-2 - Availability, mechanics, and consequences of section 336(e) election.

• § 1.336-3 - Aggregate deemed asset disposition price; various aspects of taxation of the deemed asset disposition.

• § 1.336-4 - Adjusted grossed-up basis.

• § 1.336-5 - Applicability dates.

EFFECTS ON CORPORATION

• § 1.337-1 - Nonrecognition for property distributed to parent in complete liquidation of subsidiary.

• § 1.337(d)-1 - Transitional loss limitation rule.

• § 1.337(d)-1T - [Reserved]

• § 1.337(d)-2 - Loss limitation rules.

• § 1.337(d)-3 - Gain recognition upon certain partnership transactions involving a partner's stock.

• § 1.337(d)-4 - Taxable to tax-exempt.

• § 1.337(d)-5 - Old transitional rules imposing tax on property owned by a C corporation that becomes property of a RIC or REIT

• § 1.337(d)-6 - New transitional rules imposing tax on property owned by a C corporation that becomes property of a RIC or REIT.

• § 1.337(d)-7 - Tax on property owned by a C corporation that becomes property of a RIC or REIT.

• § 1.338-0 - Outline of topics.

• § 1.338-1 - General principles; status of old target and new target.

• § 1.338-2 - Nomenclature and definitions; mechanics of the section 338 election.

• § 1.338-3 - Qualification for the section 338 election.

• § 1.338-4 - Aggregate deemed sale price; various aspects of taxation of the deemed asset sale.

• § 1.338-5 - Adjusted grossed-up basis.

• § 1.338-6 - Allocation of ADSP and AGUB among target assets.

• § 1.338-7 - Allocation of redetermined ADSP and AGUB among target assets.

• § 1.338-8 - Asset and stock consistency.

• § 1.338-9 - International aspects of section 338.

• § 1.338-10 - Filing of returns.

• § 1.338-11 - Effect of section 338 election on insurance company targets.

• § 1.338(h)(10)-1 - Deemed asset sale and liquidation.

• § 1.338(i)-1 - Effective/applicability date.

DEFINITION

• § 1.346-1 - Partial liquidation.

• § 1.346-2 - Treatment of certain redemptions.

• § 1.346-3 - Effect of certain sales.

CORPORATE ORGANIZATIONS AND REORGANIZATIONS
CORPORATE ORGANIZATIONS

• § 1.351-1 - Transfer to corporation controlled by transferor.

• § 1.351-2 - Receipt of property.

• § 1.351-3 - Records to be kept and information to be filed.

EFFECTS ON SHAREHOLDERS AND SECURITY HOLDERS

• § 1.355-4 - Non pro rata distributions, etc.

• § 1.355-5 - Records to be kept and information to be filed.

• § 1.355-6 - Recognition of gain on certain distributions of stock or securities in controlled corporation.

• § 1.355-7 - Recognition of gain on certain distributions of stock or securities in connection with an acquisition.

• § 1.355-8 - Definition of predecessor and successor and limitations on gain recognition under section 355(e) and section 355(f).

• § 1.356-1 - Receipt of additional consideration in connection with an exchange.

• § 1.356-2 - Receipt of additional consideration not in connection with an exchange.

• § 1.356-3 - Rules for treatment of securities as “other property”.

• § 1.356-4 - Exchanges for section 306 stock.

• § 1.356-5 - Transactions involving gift or compensation.

• § 1.356-6 - Rules for treatment of nonqualified preferred stock as other property.

• § 1.356-7 - Rules for treatment of nonqualified preferred stock and other preferred stock received in certain transactions.

• § 1.357-1 - Assumption of liability.

• § 1.357-2 - Liabilities in excess of basis.

• § 1.358-1 - Basis to distributees.

• § 1.358-2 - Allocation of basis among nonrecognition property.

• § 1.358-3 - Treatment of assumption of liabilities.

• § 1.358-4 - Exceptions.

• § 1.358-5 - Special rules for assumption of liabilities.

• § 1.358-6 - Stock basis in certain triangular reorganizations.

• § 1.358-7 - Transfers by partners and partnerships to corporations.

• § 1.354-1 - Exchanges of stock and securities in certain reorganizations.

• § 1.355-0 - Outline of sections.

• § 1.355-1 - Distribution of stock and securities of a controlled corporation.

• § 1.355-2 - Limitations.

• § 1.355-3 - Active conduct of a trade or business.

EFFECTS ON CORPORATION

• § 1.361-1 - Nonrecognition of gain or loss to corporations.

• § 1.362-1 - Basis to corporations.

• § 1.362-2 - Certain contributions to capital.

• § 1.362-3 - Basis of importation property acquired in loss importation transaction.

• § 1.362-4 - Basis of loss duplication property.

• § 1.367(a)-0 - Table of contents.

• § 1.367(a)-1 - Transfers to foreign corporations subject to section 367(a): In general.

• § 1.367(a)-1T - Transfers to foreign corporations subject to section 367(a): In general (temporary).

• § 1.367(a)-2 - Exceptions for transfers of property for use in the active conduct of a trade or business.

• § 1.367(a)-3 - Treatment of transfers of stock or securities to foreign corporations.

• § 1.367(a)-4 - Special rule applicable to U.S. depreciated property.

• § 1.367(a)-5 - [Reserved]

• § 1.367(a)-6 - Transfer of foreign branch with previously deducted losses.

• § 1.367(a)-6T - Transfer of foreign branch with previously deducted losses (temporary).

• § 1.367(a)-7 - Outbound transfers of property described in section 361(a) or (b).

• § 1.367(a)-8 - Gain recognition agreement requirements.

• § 1.367(a)-9T - Treatment of deemed section 351 exchanges pursuant to section 304(a)(1) (temporary).

• § 1.367(b)-0 - Table of contents.

• § 1.367(b)-1 - Other transfers.

• § 1.367(b)-2 - Definitions and special rules.

• § 1.367(b)-3 - Repatriation of foreign corporate assets in certain nonrecognition transactions.

• § 1.367(b)-3T - Repatriation of foreign corporate assets in certain nonrecognition transactions (temporary).

• § 1.367(b)-4 - Acquisition of foreign corporate stock or assets by a foreign corporation in certain nonrecognition transactions.

• § 1.367(b)-5 - Distributions of stock described in section 355.

• § 1.367(b)-6 - Effective/applicability dates and coordination rules.

• § 1.367(b)-7 - Carryover of earnings and profits and foreign income taxes in certain foreign-to-foreign nonrecognition transactions.

• § 1.367(b)-8 - Allocation of earnings and profits and foreign income taxes in certain foreign corporate separations. [Reserved]

• § 1.367(b)-9 - Special rule for F reorganizations and similar transactions.

• § 1.367(b)-10 - Acquisition of parent stock or securities for property in triangular reorganizations.

• § 1.367(b)-12 - Subsequent treatment of amounts attributed or included in income.

• § 1.367(b)-13 - Special rules for determining basis and holding period.

• § 1.367(d)-1 - Transfers of intangible property to foreign corporations.

• § 1.367(d)-1T - Transfers of intangible property to foreign corporations (temporary).

• § 1.367(e)-0 - Outline of §and 1.367(e)-2.

• § 1.367(e)-1 - Distributions described in section 367(e)(1).

• § 1.367(e)-2 - Distributions described in section 367(e)(2).

SPECIAL RULE; DEFINITIONS

• § 1.368-1 - Purpose and scope of exception of reorganization exchanges.

• § 1.368-2 - Definition of terms.

• § 1.368-3 - Records to be kept and information to be filed with returns.

INSOLVENCY REORGANIZATIONS
CARRYOVERS

• § 1.381(a)-1 - General rule relating to carryovers in certain corporate acquisitions.

• § 1.381(b)-1 - Operating rules applicable to carryovers in certain corporate acquisitions.

• § 1.381(c)(1)-1 - Net operating loss carryovers in certain corporate acquisitions.

• § 1.381(c)(1)-2 - Net operating loss carryovers; two or more dates of distribution or transfer in the taxable year.

• § 1.381(c)(2)-1 - Earnings and profits.

• § 1.381(c)(3)-1 - Capital loss carryovers.

• § 1.381(c)(4)-1 - Method of accounting.

• § 1.381(c)(5)-1 - Inventory method.

• § 1.381(c)(6)-1 - Depreciation method.

• § 1.381(c)(8)-1 - Installment method.

• § 1.381(c)(9)-1 - Amortization of bond discount or premium.

• § 1.381(c)(10)-1 - Deferred exploration and development expenditures.

• § 1.381(c)(11)-1 - Contributions to pension plan, employees' annuity plans, and stock bonus and profit-sharing plans.

• § 1.381(c)(12)-1 - Recovery of bad debts, prior taxes, or delinquency amounts.

• § 1.381(c)(13)-1 - Involuntary conversions.

• § 1.381(c)(14)-1 - Dividend carryover to personal holding company.

• § 1.381(c)(15)-1 - Indebtedness of certain personal holding companies.

• § 1.381(c)(16)-1 - Obligations of distributor or transferor corporation.

• § 1.381(c)(17)-1 - Deficiency dividend of personal holding company.

• § 1.381(c)(18)-1 - Depletion on extraction of ores or minerals from the waste or residue of prior mining.

• § 1.381(c)(19)-1 - Charitable contribution carryovers in certain acquisitions.

• § 1.381(c)(20)-1 - Carryforward of disallowed business interest.

• § 1.381(c)(21)-1 - Pre-1954 adjustments resulting from change in method of accounting.

• § 1.381(c)(22)-1 - Successor life insurance company.

• § 1.381(c)(23)-1 - Investment credit carryovers in certain corporate acquisitions.

• § 1.381(c)(24)-1 - Work incentive program credit carryovers in certain corporate acquisitions.

• § 1.381(c)(25)-1 - Deficiency dividend of a qualified investment entity.

• § 1.381(c)(26)-1 - Credit for employment of certain new employees.

• § 1.381(d)-1 - Operations loss carryovers of life insurance companies.

• § 1.382-1 - Table of contents.

• § 1.382-1T - Table of contents (temporary).

• § 1.382-2 - General rules for ownership change.

• § 1.382-2T - Definition of ownership change under section 382, as amended by the Tax Reform Act of 1986 (temporary).

• § 1.382-3 - Definitions and rules relating to a 5-percent shareholder.

• § 1.382-4 - Constructive ownership of stock.

• § 1.382-5 - Section 382 limitation.

• § 1.382-6 - Allocation of income and loss to periods before and after the change date for purposes of section 382.

• § 1.382-7 - Built-in gains and losses.

• § 1.382-8 - Controlled groups.

• § 1.382-9 - Special rules under section 382 for corporations under the jurisdiction of a court in a title 11 or similar case.

• § 1.382-10 - Special rules for determining time and manner of acquisition of an interest in a loss corporation.

• § 1.382-11 - Reporting requirements.

• § 1.382-12 - Determination of adjusted Federal long-term rate.

• § 1.383-0 - Effective date.

• § 1.383-1 - Special limitations on certain capital losses and excess credits.

• § 1.383-2 - Limitations on certain capital losses and excess credits in computing alternative minimum tax. [Reserved]

• § 1.385-1 - General provisions.

• § 1.385-3 - Certain distributions of debt instruments and similar transactions.

• § 1.385-4 - Treatment of consolidated groups.

• §§ 1.386-1.400 - §[Reserved]