Allocating previously taxed income in a Sec. 355 tax-free distribution
https://www.thetaxadviser.com/issues/2019/jul/previously-taxed-income-sec-355-tax-free-distribution.html
WebJul 1, 2019 · If the appreciated property is stock of one or more of the controlled corporate subsidiaries (Controlled) of Distributing, then Sec. 355 generally applies — which affords tax - free treatment to Distributing and its shareholders on the distribution and receipt of Controlled stock, respectively — provided that a number of requirements are satisfi...
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