Internal Revenue Code (Title 26 U.S.C.)
26 U.S.C. § 334
Basis of property received in liquidations
# (a) General rule
If property is received in a distribution in complete liquidation, and if gain or loss is recognized on receipt of such property, then the basis of the property in the hands of the distributee shall be the fair market value of such property at the time of the distribution.
# (b) Liquidation of subsidiary
(1) In general If property is received by a corporate distributee in a distribution in a complete liquidation to which section 332 applies (or in a transfer described in section 337(b)(1)), the basis of such property in the hands of such distributee shall be the same as it would be in the hands of the transferor; except that, in the hands of such distributee— (A) the basis of such property shall be the fair market value of the property at the time of the distribution in any case in which gain or loss is recognized by the liquidating corporation with respect to such property, and (B) the basis of any property described in section 362(e)(1)(B) shall be the fair market value of the property at the time of the distribution in any case in which such distributee's aggregate adjusted basis of such property would (but for this subparagraph) exceed the fair market value of such property immediately after such liquidation. (2) Corporate distributee For purposes of this subsection, the term "corporate distributee" means only the corporation which meets the stock ownership requirements specified in section 332(b).
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Nearby sections (25 sections)
- 304 · Redemption through use of related corporations
- 305 · Distributions of stock and stock rights
- 306 · Dispositions of certain stock
- 307 · Basis of stock and stock rights acquired in distributions
- 311 · Taxability of corporation on distribution
- 312 · Effect on earnings and profits
- 316 · Dividend defined
- 317 · Other definitions
- 318 · Constructive ownership of stock
- 331 · Gain or loss to shareholder in corporate liquidations
- 332 · Complete liquidations of subsidiaries
- 333 · [§333. Repealed. Pub. L. 99–514, title VI, §631(e)(3), Oct. 22,…
- 334 · Basis of property received in liquidations
- 336 · Gain or loss recognized on property distributed in complete…
- 337 · Nonrecognition for property distributed to parent in complete…
- 338 · Certain stock purchases treated as asset acquisitions
- 341 · [§341. Repealed. Pub. L. 108–27, title III, §302(e)(4)(A), May…
- 342 · [§342. Repealed. Pub. L. 94–455, title XIX, §1901(a)(47), Oct. 4,…
- 346 · Definition and special rule
- 351 · Transfer to corporation controlled by transferor
- 354 · Exchanges of stock and securities in certain reorganizations
- 355 · Distribution of stock and securities of a controlled corporation
- 356 · Receipt of additional consideration
- 357 · Assumption of liability
- 358 · Basis to distributees