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Mark Jolley
August 01, 2013 Article 1 min read
In this column, we will examine the income tax consequences of three types of nontaxable corporate transactions within the separate return context:
  1. Transfers controlled corporations under Code Sec. 351
  2. Subsidiary liquidations under Code Sec. 332
  3. Acquisitive reorganizations under Code Sec. 368(a) Unless stated otherwise, both the transferor and the transferee corporations are solvent for purposes of this tax column. The next column will explore the income tax consequences within the consolidated return context