Section 30 Liquidation Under I.R.C. 337 or by Eighty Percent Corporate Shareholder Before Sale

• Library: Bus Trans 2005

The repeal of the General Utilities doctrine—General Utilities & Operating Co. v. Helvering, 296 U.S. 200 (1935)—substantially diminished the scope of I.R.C. § 337. I.R.C. § 337 now provides that no gain or loss is recognized to the liquidating corporation upon a distribution of property to an “80-percent distributee.” I.R.C. § 337(c) defines an “80-percent distributee” as a corporation that meets the “80-percent stock ownership requirements” of I.R.C. § 332(b), which, in turn, incorporates the affiliated...