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26 C.F.R. PART 1--INCOME TAXES

TITLE 26--Internal Revenue

CHAPTER I--INTERNAL REVENUE SERVICE, DEPARTMENT OF THE TREASURY

SUBCHAPTER A--INCOME TAX

PART 1--INCOME TAXES

Table of Contents

Headings

�1.301-1

Rules applicable with respect to distributions of money and other property.

�1.302-1

General.

�1.302-2

Redemptions not taxable as dividends.

�1.302-2t

Redemptions not taxable as dividends (temporary).

�1.302-3

Substantially disproportionate redemption.

�1.302-4

Termination of shareholder's interest.

�1.302-4t

Termination of shareholder's interest (temporary).

�1.303-1

General.

�1.303-2

Requirements.

�1.303-3

Application of other sections.

�1.304-1

General.

�1.304-2

Acquisition by related corporation (other than subsidiary).

�1.304-3

Acquisition by a subsidiary.

�1.304-4t

Special rule for use of a related corporation to acquire for property the stock of another commonly owned corporation (temporary).

�1.304-5

Control.

�1.305-1

Stock dividends.

�1.305-2

Distributions in lieu of money.

�1.305-3

Disproportionate distributions.

�1.305-4

Distributions of common and preferred stock.

�1.305-5

Distributions on preferred stock.

�1.305-6

Distributions of convertible preferred.

�1.305-7

Certain transactions treated as distributions.

�1.305-8

Effective dates.

�1.306-1

General.

�1.306-2

Exception.

�1.306-3

Section 306 stock defined.

�1.307-1

General.

�1.307-2

Exception.

�1.312-1

Adjustment to earnings and profits reflecting distributions by corporations.

�1.312-2

Distribution of inventory assets.

�1.312-3

Liabilities.

�1.312-4

Examples of adjustments provided in section 312(c).

�1.312-5

Special rule for partial liquidations and certain redemptions.

�1.312-6

Earnings and profits.

�1.312-7

Effect on earnings and profits of gain or loss realized after February 28, 1913.

�1.312-8

Effect on earnings and profits of receipt of tax-free distributions requiring adjustment or allocation of basis of stock.

�1.312-9

Adjustments to earnings and profits reflecting increase in value accrued before March 1, 1913.

�1.312-10

Allocation of earnings in certain corporate separations.

�1.312-11

Effect on earnings and profits of certain other tax-free exchanges, tax-free distributions, and tax-free transfers from one corporation to another.

�1.312-12

Distributions of proceeds of loans guaranteed by the United States.

�1.312-15

Effect of depreciation on earnings and profits.

�1.316-1

Dividends.

�1.316-2

Sources of distribution in general.

�1.317-1

Property defined.

�1.318-1

Constructive ownership of stock; introduction.

�1.318-2

Application of general rules.

�1.318-3

Estates, trusts, and options.

�1.318-4

Constructive ownership as actual ownership; exceptions.

�1.331-1

Corporate liquidations.

�1.331-1t

Corporate liquidations (temporary).

�1.332-1

Distributions in liquidation of subsidiary corporation; general.

�1.332-2

Requirements for nonrecognition of gain or loss.

�1.332-3

Liquidations completed within one taxable year.

�1.332-4

Liquidations covering more than one taxable year.

�1.332-5

Distributions in liquidation as affecting minority interests.

�1.332-6t

Records to be kept and information to be filed with return (temporary).

�1.332-7

Indebtedness of subsidiary to parent.

�1.334-1

Basis of property received in liquidations.

�1.337(d)-1

Transitional loss limitation rule.

�1.337(d)-1t

[Reserved]

�1.337(d)-2

Loss limitation rules.

�1.337(d)-4

Taxable to tax-exempt.

�1.337(d)-5

Old transitional rules imposing tax on property owned by a C corporation that becomes property of a RIC or REIT

�1.337(d)-6

New transitional rules imposing tax on property owned by a C corporation that becomes property of a RIC or REIT.

�1.337(d)-7

Tax on property owned by a C corporation that becomes property of a RIC or REIT.

�1.338-0

Outline of topics.

�1.338-1

General principles; status of old target and new target.

�1.338-2

Nomenclature and definitions; mechanics of the section 338 election.

�1.338-3

Qualification for the section 338 election.

�1.338-4

Aggregate deemed sale price; various aspects of taxation of the deemed asset sale.

�1.338-5

Adjusted grossed-up basis.

�1.338-6

Allocation of ADSP and AGUB among target assets.

�1.338-6t

Allocation of ADSP and AGUB among target assets (temporary).

�1.338-7

Allocation of redetermined ADSP and AGUB among target assets.

�1.338-8

Asset and stock consistency.

�1.338-9

International aspects of section 338.

�1.338-10

Filing of returns.

�1.338-10t

Filing of returns (temporary).

�1.338-11

Effect of section 338 election on insurance company targets.

�1.338-11t

Effect of section 338 election on insurance company targets (temporary).

�1.338(h)(10)-1

Deemed asset sale and liquidation.

�1.338(i)-1

Effective dates.

�1.341-1

Collapsible corporations; in general.

�1.341-2

Definitions.

�1.341-3

Presumptions.

�1.341-4

Limitations on application of section.

�1.341-5

Application of section.

�1.341-6

Exceptions to application of section.

�1.341-7

Certain sales of stock of consenting corporations.

�1.342-1

General.

�1.346-1

Partial liquidation.

�1.346-2

Treatment of certain redemptions.

�1.346-3

Effect of certain sales.

�1.351-1

Transfer to corporation controlled by transferor.

�1.351-2

Receipt of property.

�1.351-3t

Records to be kept and information to be filed (temporary).

�1.354-1

Exchanges of stock and securities in certain reorganizations.

�1.355-0

Outline of sections.

�1.355-1

Distribution of stock and securities of a controlled corporation.

�1.355-2

Limitations.

�1.355-3

Active conduct of a trade or business.

�1.355-4

Non pro rata distributions, etc.

�1.355-5t

Records to be kept and information to be filed (temporary).

�1.355-6

Recognition of gain on certain distributions of stock or securities in controlled corporation.

�1.355-7

Recognition of gain on certain distributions of stock or securities in connection with an acquisition.

�1.356-1

Receipt of additional consideration in connection with an exchange.

�1.356-2

Receipt of additional consideration not in connection with an exchange.

�1.356-3

Rules for treatment of securities as ''other property''.

�1.356-4

Exchanges for section 306 stock.

�1.356-5

Transactions involving gift or compensation.

�1.356-6

Rules for treatment of nonqualified preferred stock as other property.

�1.356-7

Rules for treatment of nonqualified preferred stock and other preferred stock received in certain transactions.

�1.357-1

Assumption of liability.

�1.357-2

Liabilities in excess of basis.

�1.358-1

Basis to distributees.

�1.358-2

Allocation of basis among nonrecognition property.

�1.358-3

Treatment of assumption of liabilities.

�1.358-4

Exceptions.

�1.358-5

[Reserved]

�1.358-5t

Special rules for assumption of liabilities (temporary).

�1.358-6

Stock basis in certain triangular reorganizations.

�1.358-7

Transfers by partners and partnerships to corporations.

�1.361-1

Nonrecognition of gain or loss to corporations.

�1.362-1

Basis to corporations.

�1.362-2

Certain contributions to capital.

�1.367(a)-1t

Transfers to foreign corporations subject to section 367(a): In general (temporary).

�1.367(a)-2t

Exception for transfers of property for use in the active conduct of a trade or business (temporary).

�1.367(a)-3

Treatment of transfers of stock or securities to foreign corporations.

�1.367(a)-4t

Special rules applicable to specified transfers of property (temporary).

�1.367(a)-5t

Property subject to section 367(a)(1) regardless of use in trade or business (temporary).

�1.367(a)-6t

Transfer of foreign branch with previously deducted losses (temporary).

�1.367(a)-8

Gain recognition agreement requirements.

�1.367(b)-0

Table of contents.

�1.367(b)-1

Other transfers.

�1.367(b)-2

Definitions and special rules.

�1.367(b)-3

Repatriation of foreign corporate assets in certain nonrecognition transactions.

�1.367(b)-3t

Repatriation of foreign corporate assets in certain nonrecognition transactions (temporary).

�1.367(b)-4

Acquisition of foreign corporate stock or assets by a foreign corporation in certain nonrecognition transactions.

�1.367(b)-5

Distributions of stock described in section 355.

�1.367(b)-6

Effective dates and coordination rules.

�1.367(b)-7

Carryover of earnings and profits and foreign income taxes in certain foreign-to-foreign nonrecognition transactions.

�1.367(b)-8

Allocation of earnings and profits and foreign income taxes in certain foreign corporate separations.--[Reserved]

�1.367(b)-9

Special rule for F reorganizations and similar transactions.

�1.367(b)-12

Subsequent treatment of amounts attributed or included in income.

�1.367(b)-13

Special rules for determining basis and holding period.

�1.367(d)-1t

Transfers of intangible property to foreign corporations (temporary).

�1.367(e)-0

Outline of 1.367(e)-1 and 1.367(e)-2.

�1.367(e)-1

Distributions described in section 367(e)(1).

�1.367(e)-2

Distributions described in section 367(e)(2).

�1.368-1

Purpose and scope of exception of reorganization exchanges.

�1.368-2

Definition of terms.

�1.368-3t

Records to be kept and information to be filed with returns (temporary).

�1.371-1

Exchanges by corporations.

�1.371-2

Exchanges by security holders.

�1.372-1

Corporations.

�1.374-1

Exchanges by insolvent railroad corporations.

�1.374-2

Basis of property acquired after December 31, 1938, by railroad corporation in a receivership or railroad reorganization proceeding.

�1.374-3

Records to be kept and information to be filed.

�1.374-4

Property acquired by electric railway corporation in corporate reorganizing proceeding.

�1.381(a)-1

General rule relating to carryovers in certain corporate acquisitions.

�1.381(b)-1

Operating rules applicable to carryovers in certain corporate acquisitions.

�1.381(b)-1t

Operating rules applicable to carryovers in certain corporate acquisitions (temporary).

�1.381(c)(1)-1

Net operating loss carryovers in certain corporate acquisitions.

�1.381(c)(1)-2

Net operating loss carryovers; two or more dates of distribution or transfer in the taxable year.

�1.381(c)(2)-1

Earnings and profits.

�1.381(c)(3)-1

Capital loss carryovers.

�1.381(c)(4)-1

Method of accounting.

�1.381(c)(5)-1

Inventories.

�1.381(c)(6)-1

Depreciation method.

�1.381(c)(8)-1

Installment method.

�1.381(c)(9)-1

Amortization of bond discount or premium.

�1.381(c)(10)-1

Deferred exploration and development expenditures.

�1.381(c)(11)-1

Contributions to pension plan, employees' annuity plans, and stock bonus and profit-sharing plans.

�1.381(c)(12)-1

Recovery of bad debts, prior taxes, or delinquency amounts.

�1.381(c)(13)-1

Involuntary conversions.

�1.381(c)(14)-1

Dividend carryover to personal holding company.

�1.381(c)(15)-1

Indebtedness of certain personal holding companies.

�1.381(c)(16)-1

Obligations of distributor or transferor corporation.

�1.381(c)(17)-1

Deficiency dividend of personal holding company.

�1.381(c)(18)-1

Depletion on extraction of ores or minerals from the waste or residue of prior mining.

�1.381(c)(19)-1

Charitable contribution carryovers in certain acquisitions.

�1.381(c)(21)-1

Pre-1954 adjustments resulting from change in method of accounting.

�1.381(c)(22)-1

Successor life insurance company.

�1.381(c)(23)-1

Investment credit carryovers in certain corporate acquisitions.

�1.381(c)(24)-1

Work incentive program credit carryovers in certain corporate acquisitions.

�1.381(c)(25)-1

Deficiency dividend of a qualified investment entity.

�1.381(c)(26)-1

Credit for employment of certain new employees.

�1.381(d)-1

Operations loss carryovers of life insurance companies.

�1.382-1

Table of contents.

�1.382-1t

[Reserved]

�1.382-2

General rules for ownership change.

�1.382-2t

Definition of ownership change under section 382, as amended by the Tax Reform Act of 1986 (temporary).

�1.382-3

Definitions and rules relating to a 5-percent shareholder.

�1.382-4

Constructive ownership of stock.

�1.382-5

Section 382 limitation.

�1.382-6

Allocation of income and loss to periods before and after the change date for purposes of section 382.

�1.382-7

Built-in gains and losses.--[Reserved]

�1.382-8

Controlled groups.

�1.382-8t

Controlled groups (temporary).

�1.382-9

Special rules under section 382 for corporations under the jurisdiction of a court in a title 11 or similar case.

�1.382-10

Special rules for determining time and manner of acquisition of an interest in a loss corporation.

�1.382-11t

Reporting requirements (temporary).

�1.383-0

Effective date.

�1.383-1

Special limitations on certain capital losses and excess credits.

�1.383-2

Limitations on certain capital losses and excess credits in computing alternative minimum tax.--[Reserved]