§331. Gain or loss to shareholder in corporate liquidations — Inbound Citations
26 U.S.C. § 331
Cited by 6 provisions in release 119-102.
Citations to 26 U.S.C. § 331 as a whole
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(2) For distributions in complete liquidation, see part II (sec. 331 and following).
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(A) subsection (a) and section 331 shall not apply to such distribution, and
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(3) If the distributee of a distribution described in paragraph (1) is a controlled foreign corporation (as defined in section 957), then notwithstanding paragraph (1) or subsection (a), such distribution shall be treated as a distribution to which section 331 applies.
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(A) If, in a liquidation to which section 331 applies, the shareholder receives (in exchange for the shareholder’s stock) an installment obligation acquired in respect of a sale or exchange by the corporation during the 12-month period beginning on the date a plan of complete liquidation is adopted and the liquidation is completed during such 12-month period, then, for purposes of this section, the receipt of payments under such obligation (but not the receipt of such obligation) by the shareholder shall be treated as the receipt of payment for the stock.
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(C) If a distribution by a real estate investment trust is treated as a sale or exchange of stock under section 301(c)(3), 302, or 331 with respect to a qualified shareholder—(i) in the case of an applicable investor, subparagraph (B) shall apply with respect to such distribution, and(ii) in the case of any other person, such distribution shall be treated under section 857(b)(3)(F)1 as a dividend from a real estate investment trust notwithstanding any other provision of this title.