Tax attributes of liquidating corporations

Those protections have developed in the form of Tax Attribute Protection (TAP) Plans or Charter Amendments.

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Ownership Change Limitations - Section 382 Introductory Material A.

Carrybacks of Consolidated Net Operating Losses III.

Transfers Involving First-Tier and Higher-Tier Entities e.

Segregation Transactions (1) Equity Structure Shifts (2) Stock Issuances (3) “B” Reorganizations (4) Redemptions (5) Options d. Exceptions (1) Small Issuance Exception (2) Cash Issuance Exception (3) Applications (4) Effective Dates h.

Publicly Held Corporations (1) Reliance on SEC Filings (2) Ownership by Mutual Funds and Pension Plans (3) Stock Transfer Restrictions f.

Three Factors (1) Growth Potential (2) Resulting in an Ownership Change (3) Excess Pre-Change Losses 2.

Acquisitions in Which the Net Operating Loss May Carry Over 1.

No Transfer to Parent in “Purchase-Type” Transaction (1) Section 338 (2) Effect of a Liquidation c.

If Post-acquisition Income Does Not Exceed Aggregate Carryovers c.

Qualifying Reorganizations and Liquidations Within a Consolidated Group H.

Mid-Year Change (1) Daily Proration (2) Notice 87-79 (3) Private Letter Rulings (4) Final Regulations (a) Special Operating Rules (b) Consistency with Section 383 (c) Alternative Minimum Tax (d) Consolidated Return Allocations (e) Netting Income and Loss of the Change Year (f) Filing Extensions F.