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Corporate Organization, Structure, and Nonliquidating Distributions

Using Checkpoint, identify a court case involving a Section 351 transaction. What are the major issues involved in the case and what are the implications of this case?

Chapters 18 & 19 in South-Western Federal Taxation 2019

Redemption Through Use of Related Corporations, 26 USC §304

Narotzki, D., & McCoskey, M. (2018). An attempt to distinguish between a section 351 transfer and a B reorganization. The ATA Journal of Legal Tax Research, 16(1), 17.

Alstadsæter, A., Jacob, M., & Michaely, R. (July 2017). Do dividend taxes affect corporate investment? Journal of Public Economics, 151(C), 74-83.

Assumption of liability, 26 U.S. Code § 357 (n.d.). Retrieved from Thomson Reuters Checkpoint database.

Basis to corporations, 26 U.S. Code § 362 (n.d.). Retrieved from Thomson Reuters Checkpoint database.

Basis to distributees, 26 U.S. Code § 358 (n.d.). Retrieved from Thomson Reuters Checkpoint database.

Complete liquidations of subsidiaries, 26 U.S. Code § 332 (n.d.). Retrieved from Thomson Reuters Checkpoint database.

Definitions relating to corporate reorganizations, 26 U.S. Code § 368 (n.d.). Retrieved from Thomson Reuters Checkpoint database.

Distributions of property, 26 U.S. Code § 301 (n.d.). Retrieved from Thomson Reuters Checkpoint database.

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