Treasury Regulations (26 C.F.R.)
26 CFR § 1.1059(e)-1
Non-pro rata redemptions.
# (a) In general.
Section 1059(d)(6) (exception where stock held during entire existence of corporation) and section 1059(e)(2) (qualifying dividends) do not apply to any distribution treated as an extraordinary dividend under section 1059(e)(1). For example, if a redemption of stock is not pro rata as to all shareholders, any amount treated as a dividend under section 301 is treated as an extraordinary dividend regardless of whether the dividend is a qualifying dividend.
# (b) Reorganizations.
For purposes of section 1059(e)(1), any exchange under section 356 is treated as a redemption and, to the extent any amount is treated as a dividend under section 356(a)(2), it is treated as a dividend under section 301.
# (c) Effective date.
This section applies to distributions announced (within the meaning of section 1059(d)(5)) on or after June 17, 1996.
[T.D. 8724, 62 FR 38028, July 16, 1997]
Source: view the official text
In this part (40 sections)
- 1.1037-1 · Certain exchanges of United States obligations.
- 1.1038-1 · Reacquisitions of real property in satisfaction of…
- 1.1038-2 · Reacquisition and resale of property used as a principal…
- 1.1038-3 · Election to have section 1038 apply for taxable years…
- 1.1039-1 · Certain sales of low-income housing projects.
- 1.1041-1T · Treatment of transfer of property between spouses or…
- 1.1041-2 · Redemptions of stock.
- 1.1042-1T · Questions and answers relating to the sales of stock to…
- 1.1044(a)-1 · Time and manner for making election under the Omnibus…
- 1.1045-1 · Application to partnerships.
- 1.1051-1 · Basis of property acquired during affiliation.
- 1.1052-1 · Basis of property established by Revenue Act of 1932.
- 1.1052-2 · Basis of property established by Revenue Act of 1934.
- 1.1052-3 · Basis of property established by the Internal Revenue Code…
- 1.1053-1 · Property acquired before March 1, 1913.
- 1.1054-1 · Certain stock of Federal National Mortgage Association.
- 1.1055-1 · General rule with respect to redeemable ground rents.
- 1.1055-2 · Determination of amount realized on the transfer of the…
- 1.1055-3 · Basis of real property held subject to liabilities under a…
- 1.1055-4 · Basis of redeemable ground rent reserved or created in…
- 1.1059(e)-1 · Non-pro rata redemptions.
- 1.1059A-1 · Limitation on taxpayer's basis or inventory cost in…
- 1.1060-1 · Special allocation rules for certain asset acquisitions.
- 1.1061-0 · Table of contents.
- 1.1061-1 · Section 1061 definitions.
- 1.1061-2 · Applicable partnership interests and applicable trades or…
- 1.1061-3 · Exceptions to the definition of an API.
- 1.1061-4 · Section 1061 computations.
- 1.1061-5 · Section 1061(d) transfers to related persons.
- 1.1061-6 · Reporting rules.
- 1.1071-1 · Gain from sale or exchange to effectuate policies of Federal…
- 1.1071-2 · Nature and effect of election.
- 1.1071-3 · Reduction of basis of property pursuant to election under…
- 1.1071-4 · Manner of election.
- 1.1081-1 · Terms used.
- 1.1081-2 · Purpose and scope of exception.
- 1.1081-3 · Exchanges of stock or securities solely for stock or…
- 1.1081-4 · Exchanges of property for property by corporations.
- 1.1081-5 · Distribution solely of stock or securities.
- 1.1081-6 · Transfers within system group.