A Guide to the Tax Treatment of Corporate Liquidation.
本文分析了公司清算中影响税务后果的多种因素(如股东类型、母公司资格、清算选择),并提供了决策表,帮助学生理解相关税法条款。
Abstract The tax consequences of a particular corporate liquidation depend on many factors, e.g., whether or not the shareholder is a corporation, whether or not a corporate shareholder qualifies as the "parent" corporation, and whether or not certain elections have been made with respect to the liquidation. Different combinations of factors will result in different tax consequences. Tax consequences must be considered at the shareholder level and at the corporate level. In order to simplify the initial analysis of the tax consequences which may result from a corporate liquidation, decision tables were prepared for use by students involved in the study of corporate liquidations. General explanations of the applicable Internal Revenue Code provisions accompany the tables.