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October 1, 2013 Article 1 min read
In this column, we will explore the income tax consequences of debt extinguishment in three types of nontaxable corporate transactions when both the debtor and creditor are members of a consolidated return group:
  1. Transfers to 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.