§1367. Adjustments to basis of stock of shareholders, etc. — Inbound Citations
26 U.S.C. § 1367
Cited by 12 provisions in release 119-102.
Citations to 26 U.S.C. § 1367 as a whole
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(17) to the extent provided in section 1367 in the case of stock of, and indebtedness owed to, shareholders of an S corporation;
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(1) the adjustments to the basis of the shareholder’s stock described in section 1367, and
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(A) Except as otherwise provided in this paragraph, the term “accumulated adjustments account” means an account of the S corporation which is adjusted for the S period in a manner similar to the adjustments under section 1367 (except that no adjustment shall be made for income (and related expenses) which is exempt from tax under this title and the phrase “(but not below zero)” shall be disregarded in section 1367(a)(2)) and no adjustment shall be made for Federal taxes attributable to any taxable year in which the corporation was a C corporation.
Citations to §1367(a)(1)
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(A) the adjusted basis of the shareholder’s stock in the S corporation (determined with regard to paragraphs (1) and (2)(A) of section 1367(a) for the taxable year), and
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(1) the adjustments to the basis of the shareholder’s stock described in section 1367, and(2) the adjustments to the accumulated adjustments account which are required by subsection (e)(1).In the case of any distribution made during any taxable year, the adjusted basis of the stock shall be determined with regard to the adjustments provided in paragraph (1) of section 1367(a) for the taxable year.
Citations to §1367(a)(1)(A)
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(A) shall be treated as income exempt from tax for purposes of sections 705(a)(1)(B) and 1367(a)(1)(A), and
Citations to §1367(a)(2)
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(4) In the case of any charitable contribution of property to which the second sentence of section 1367(a)(2) applies, paragraph (1) shall not apply to the extent of the excess (if any) of—(A) the shareholder’s pro rata share of such contribution, over(B) the shareholder’s pro rata share of the adjusted basis of such property.
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(A) Except as otherwise provided in this paragraph, the term “accumulated adjustments account” means an account of the S corporation which is adjusted for the S period in a manner similar to the adjustments under section 1367 (except that no adjustment shall be made for income (and related expenses) which is exempt from tax under this title and the phrase “(but not below zero)” shall be disregarded in section 1367(a)(2)) and no adjustment shall be made for Federal taxes attributable to any taxable year in which the corporation was a C corporation.
Citations to §1367(a)(2)(A)
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(A) the adjusted basis of the shareholder’s stock in the S corporation (determined with regard to paragraphs (1) and (2)(A) of section 1367(a) for the taxable year), and
Citations to §1367(a)(2)(D)
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(5) Sections 1367(a)(2)(D) and 1371(c)(1) shall not apply with respect to any increase in the tax imposed by reason of this subsection.
Citations to §1367(b)(2)
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(C) For purposes of subsection (e)(6), a shareholder’s adjusted basis in indebtedness of an S corporation shall be determined without regard to any adjustments made under section 1367(b)(2).
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(B) the shareholder’s adjusted basis of any indebtedness of the S corporation to the shareholder (determined without regard to any adjustment under paragraph (2) of section 1367(b) for the taxable year).