C:6-8 In many cases, usually no because the two alternatives results are the same. A
corporation’s shareholders recognize the distributions gain or loss when a corporation recognizes
its gains and losses, sells its assets, and pays its taxes. If the...
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C:6-8 In many cases, usually no because the two alternatives results are the same. A
corporation’s shareholders recognize the distributions gain or loss when a corporation recognizes
its gains and losses, sells its assets, and pays its taxes. If the corporation’s assets are distributed
directly to the shareholders, it will still recognize gain or losses as if it sold its assets. Then the
corporation would pay its taxes and distribute the remaining assets to its shareholders. Under the
first alternative, the distributed assets FMV must be the same amount as the distributed cash.
Since shareholders take a FMV basis in the distributed assets, shareholders recognize the same
gain or loss. Shareholders do not recognize further gain or loss upon selling assets. The results
may be different if the corporation under Sec 336(d) is subject to loss limitations upon property
distribution to certain shareholders. The limitations of Sec 336 do not apply to direct sales by the
corporation to outside
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