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Home Page > Executive Branch > Code of Federal Regulations > Electronic Code of Federal Regulations
e-CFR Data is current as of November 3, 2008
TITLE 26--Internal Revenue
CHAPTER I--INTERNAL REVENUE SERVICE, DEPARTMENT OF THE TREASURY
SUBCHAPTER A--INCOME TAX
PART 1--INCOME TAXES
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| Rules applicable with respect to distributions of money and other property. |
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| Redemptions not taxable as dividends. |
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| Substantially disproportionate redemption. |
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| Termination of shareholder's interest. |
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| Application of other sections. |
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| Acquisition by related corporation (other than subsidiary). |
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| Acquisition by a subsidiary. |
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| Special rule for use of a related corporation to acquire for property the stock of another commonly owned corporation (temporary). |
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| Distributions in lieu of money. |
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| Disproportionate distributions. |
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| Distributions of common and preferred stock. |
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| Distributions on preferred stock. |
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| Distributions of convertible preferred. |
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| Certain transactions treated as distributions. |
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| Section 306 stock defined. |
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| Adjustment to earnings and profits reflecting distributions by corporations. |
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| Distribution of inventory assets. |
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| Examples of adjustments provided in section 312(c). |
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| Special rule for partial liquidations and certain redemptions. |
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| Effect on earnings and profits of gain or loss realized after February 28, 1913. |
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| Effect on earnings and profits of receipt of tax-free distributions requiring adjustment or allocation of basis of stock. |
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| Adjustments to earnings and profits reflecting increase in value accrued before March 1, 1913. |
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| Allocation of earnings in certain corporate separations. |
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| Effect on earnings and profits of certain other tax-free exchanges, tax-free distributions, and tax-free transfers from one corporation to another. |
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| Distributions of proceeds of loans guaranteed by the United States. |
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| Effect of depreciation on earnings and profits. |
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| Sources of distribution in general. |
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| Constructive ownership of stock; introduction. |
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| Application of general rules. |
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| Estates, trusts, and options. |
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| Constructive ownership as actual ownership; exceptions. |
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| Distributions in liquidation of subsidiary corporation; general. |
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| Requirements for nonrecognition of gain or loss. |
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| Liquidations completed within one taxable year. |
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| Liquidations covering more than one taxable year. |
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| Distributions in liquidation as affecting minority interests. |
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| Records to be kept and information to be filed with return. |
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| Indebtedness of subsidiary to parent. |
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| Basis of property received in liquidations. |
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| Transitional loss limitation rule. |
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| Old transitional rules imposing tax on property owned by a C corporation that becomes property of a RIC or REIT |
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| New transitional rules imposing tax on property owned by a C corporation that becomes property of a RIC or REIT. |
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| Tax on property owned by a C corporation that becomes property of a RIC or REIT. |
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| General principles; status of old target and new target. |
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| Nomenclature and definitions; mechanics of the section 338 election. |
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| Qualification for the section 338 election. |
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| Aggregate deemed sale price; various aspects of taxation of the deemed asset sale. |
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| Adjusted grossed-up basis. |
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| Allocation of ADSP and AGUB among target assets. |
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| Allocation of redetermined ADSP and AGUB among target assets. |
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| Asset and stock consistency. |
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| International aspects of section 338. |
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| Effect of section 338 election on insurance company targets. |
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| Deemed asset sale and liquidation. |
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| Effective/applicability date. |
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| Collapsible corporations; in general. |
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| Limitations on application of section. |
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| Exceptions to application of section. |
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| Certain sales of stock of consenting corporations. |
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| Treatment of certain redemptions. |
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| Transfer to corporation controlled by transferor. |
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| Records to be kept and information to be filed. |
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| Exchanges of stock and securities in certain reorganizations. |
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| Distribution of stock and securities of a controlled corporation. |
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| Active conduct of a trade or business. |
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| Non pro rata distributions, etc. |
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| Records to be kept and information to be filed. |
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| Recognition of gain on certain distributions of stock or securities in controlled corporation. |
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| Recognition of gain on certain distributions of stock or securities in connection with an acquisition. |
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| Receipt of additional consideration in connection with an exchange. |
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| Receipt of additional consideration not in connection with an exchange. |
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| Rules for treatment of securities as ''other property''. |
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| Exchanges for section 306 stock. |
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| Transactions involving gift or compensation. |
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| Rules for treatment of nonqualified preferred stock as other property. |
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| Rules for treatment of nonqualified preferred stock and other preferred stock received in certain transactions. |
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| Liabilities in excess of basis. |
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| Allocation of basis among nonrecognition property. |
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| Treatment of assumption of liabilities. |
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| Special rules for assumption of liabilities. |
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| Stock basis in certain triangular reorganizations. |
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| Transfers by partners and partnerships to corporations. |
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| Nonrecognition of gain or loss to corporations. |
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| Certain contributions to capital. |
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| Limitations on built-in loss duplication. |
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| Transfers to foreign corporations subject to section 367(a): In general (temporary). |
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| Exception for transfers of property for use in the active conduct of a trade or business (temporary). |
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| Treatment of transfers of stock or securities to foreign corporations. |
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| Treatment of transfers of stock or securities to foreign corporations (temporary). |
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| Special rules applicable to specified transfers of property (temporary). |
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| Property subject to section 367(a)(1) regardless of use in trade or business (temporary). |
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| Transfer of foreign branch with previously deducted losses (temporary). |
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| Gain recognition agreement requirements. |
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| Gain recognition agreement requirements (temporary). |
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| Definitions and special rules. |
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| Repatriation of foreign corporate assets in certain nonrecognition transactions. |
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| Repatriation of foreign corporate assets in certain nonrecognition transactions (temporary). |
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| Acquisition of foreign corporate stock or assets by a foreign corporation in certain nonrecognition transactions. |
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| Distributions of stock described in section 355. |
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| Effective dates and coordination rules. |
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| Carryover of earnings and profits and foreign income taxes in certain foreign-to-foreign nonrecognition transactions. |
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| Allocation of earnings and profits and foreign income taxes in certain foreign corporate separations.--[Reserved] |
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| Special rule for F reorganizations and similar transactions. |
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| Subsequent treatment of amounts attributed or included in income. |
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| Special rules for determining basis and holding period. |
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| Acquisition of parent stock for property in triangular reorganizations (temporary). |
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| Transfers of intangible property to foreign corporations (temporary). |
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| Outline of 1.367(e)-1 and 1.367(e)-2. |
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| Distributions described in section 367(e)(1). |
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| Distributions described in section 367(e)(2). |
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| Purpose and scope of exception of reorganization exchanges. |
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| Purpose and scope of exception of reorganization exchanges (temporary). |
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| Definition of terms (temporary). |
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| Records to be kept and information to be filed with returns. |
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| General rule relating to carryovers in certain corporate acquisitions. |
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| Operating rules applicable to carryovers in certain corporate acquisitions. |
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| Net operating loss carryovers in certain corporate acquisitions. |
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| Net operating loss carryovers; two or more dates of distribution or transfer in the taxable year. |
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| Amortization of bond discount or premium. |
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| Deferred exploration and development expenditures. |
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| Contributions to pension plan, employees' annuity plans, and stock bonus and profit-sharing plans. |
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| Recovery of bad debts, prior taxes, or delinquency amounts. |
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| Dividend carryover to personal holding company. |
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| Indebtedness of certain personal holding companies. |
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| Obligations of distributor or transferor corporation. |
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| Deficiency dividend of personal holding company. |
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| Depletion on extraction of ores or minerals from the waste or residue of prior mining. |
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| Charitable contribution carryovers in certain acquisitions. |
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| Pre-1954 adjustments resulting from change in method of accounting. |
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| Successor life insurance company. |
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| Investment credit carryovers in certain corporate acquisitions. |
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| Work incentive program credit carryovers in certain corporate acquisitions. |
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| Deficiency dividend of a qualified investment entity. |
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| Credit for employment of certain new employees. |
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| Operations loss carryovers of life insurance companies. |
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| General rules for ownership change. |
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| Definition of ownership change under section 382, as amended by the Tax Reform Act of 1986 (temporary). |
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| Definitions and rules relating to a 5-percent shareholder. |
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| Constructive ownership of stock. |
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| Allocation of income and loss to periods before and after the change date for purposes of section 382. |
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| Built-in gains and losses.--[Reserved] |
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| Built-in gains and losses (temporary). |
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| Special rules under section 382 for corporations under the jurisdiction of a court in a title 11 or similar case. |
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| Special rules for determining time and manner of acquisition of an interest in a loss corporation. |
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| Special limitations on certain capital losses and excess credits. |
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| Limitations on certain capital losses and excess credits in computing alternative minimum tax.--[Reserved] |
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February 27, 2007< !-- #EndDate -- >-->
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