Dividend distribution prior to an F reorganization

Letter Ruling 9902004 now holds that a corporation can dispose of unwanted assets in a Sec. 301 distribution before conducting an F reorganization, provided that there is a time gap between the distribution and the F reorganization. Letter Ruling 9902004 involved a corporation that had elected to be...

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Bibliographic Details
Published inThe Tax Adviser Vol. 30; no. 5; p. 288
Main Authors Barnes, Donald A, Luchs, Lorin D
Format Magazine Article Trade Publication Article
LanguageEnglish
Published New York American Institute of CPA's 01.05.1999
American Institute of Certified Public Accountants
Subjects
Corporate distributions
Corporate reorganization
Corporate reorganizations
Corporate taxes
Disregarded entities
Dividend distributions
Foreign owned US companies
Laws, regulations and rules
Letter rulings
Limited liability companies
Limited partnerships
Ltr. Rul. 9902004
Recognition of gain or loss (Taxation)
REITs
Stockholders
Tax law
Taxation
United States
United States > US
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Summary:Letter Ruling 9902004 now holds that a corporation can dispose of unwanted assets in a Sec. 301 distribution before conducting an F reorganization, provided that there is a time gap between the distribution and the F reorganization. Letter Ruling 9902004 involved a corporation that had elected to be treated as a real estate investment trust (REIT) for Federal income tax purposes.
ISSN:0039-9957