Tax treatment liquidating distribution foreign passive investment

Finally, the Portfolio reviews the issues arising from the liquidation of insolvent subsidiaries and the existence of intercorporate debt in subsidiary liquidations. Subsidiary Liquidations Not Qualifying Under § 332 IV.

shareholders of foreign corporations are generally not subject to tax on the earnings of such corporations until the earnings are repatriated to the shareholders in the form of a dividend.

The Portfolio also discusses the tax treatment of liquidations before the repeal of that doctrine., the Portfolio considers the tax consequences to both the liquidating corporation and its shareholders.

The Portfolio highlights traps for unwary taxpayers and discusses planning opportunities in connection with a corporate liquidation.

784, analyses the tax considerations in connection with the liquidation of a corporation.

The principal focus of the Portfolio is on liquidations after the repeal of the General Utilities doctrine by the Tax Reform Act of 1986.

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Distributions to Minority Shareholders and to Tax-Exempt 80% Distributees VI.

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