Reporting liquidating distributions


07-Aug-2017 01:57

He is a frequent speaker on transfer pricing matters, has co-authored the chapter in the Bureau of National Affairs' Tax Practice Series on Transfer Pricing, and has authored articles on transfer pricing issues. A., magna cum laude, from the University of Dayton, a J. from American University Washington College of Law, and an LL. While there, she focused on inbound tax matters, including withholding and information reporting under §§1441/1442, 1445, and 1446 and tax treaty issues. In this position, she was responsible for reviewing matters relating to the application of the international provisions to partnerships.

The shareholder reports the payments received on the installment method unless the shareholder elects otherwise in accordance with § 15a.453-1(d) of this chapter.All amounts distributed or treated as distributed to a qualifying shareholder incident to the liquidation, including cash, the issue price of qualifying installment obligations as determined under paragraph (a)(2)(ii)(A) of this section, and the fair market value of other property (including obligations that are not qualifying installment obligations) are considered as having been received by the shareholder as the selling price (as defined in § 15a.453-1(b)(2)(ii) of this chapter) for the shareholder's stock in the liquidating corporation.



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