Section 37 Application of Stock Distribution Rules to Recapitalizations

• Library: Bus Trans 2005

I.R.C. § 305(b)(2) provides that a stock distribution may be taxable under the stock distribution rules if the distribution has the result of the receipt of property by some shareholders and an increase in the proportionate interest of other shareholders in the corporation. I.R.C. § 305(b)(3) provides for the taxation of a stock distribution (or a series of distributions) involving the receipt of preferred stock by some common shareholders and the receipt of common stock by other common shareholders. I.R.C. § 305(c) provides that a recapitalization may be subject to the I.R.C. §...