WebSection 317(a) defines "property" for the purposes of the corporate distribution provisions as money, securities, and any other property, except for stock, or rights to acquire stock, in … WebInternal Revenue Code Section 317(b) Other definitions (a) Property. For purposes of this part, the term "property" means money, securities, and any other property; except that …
2006 INTERNATIONAL RESIDENTIAL CODE (IRC) ICC DIGITAL …
Webdefined in section 317(b). FACTS Notice 2001-45, 2001-33 I.R.B. 120, announced that the Service will challenge transactions identified as section 302 basis shifting tax shelters and disallow the federal income tax benefits purportedly derived from such transactions. Notice 2001-45 provides a brief description of the steps undertaken in the typical Web3013 of the Internal Revenue Code of 1954. Filing a petition in the Tax Court, taxpayer claimed that the transaction qualified under Section 3514 and ... ing of section 317(b)), and if subsection (a) of this section does not apply, such redemption shall be treated as a distribution of property to which section 301 applies. 3. SEC. 301 ... city beach haarlem
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WebI.R.C. § 317(b) Redemption Of Stock — For purposes of this part, stock shall be treated as redeemed by a corporation if the corporation acquires its stock from a shareholder in … WebMar 1, 2024 · Section 317(b) redemptions include cash consideration funded by a target covered corporation in taxable acquisitions, including in leveraged buyouts where the target corporation assumes acquiror debt. WebIf a corporation redeems its stock (within the meaning of section 317 (b) ), and if paragraph (1), (2), (3), (4), or (5) of subsection (b) applies, such redemption shall be treated as a … city beach hats women\\u0027s