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13-Oct-2019 19:49

In general, shareholders that are parties to a nontaxable reorganization do not recognize gain or loss with respect to exchanges of stock and securities in such reorganization. subsidiaries have substantially increased in value and that one or more of the companies has excess cash that it desires to repatriate to Brazil without incurring U.

Under Section 356, however, a recipient of money or other property (boot) in a nontaxable reorganization recognizes gain (if any) on the transaction in an amount not in excess of the sum of such money and the fair market value of such other property.

In general, a CFC is a foreign corporation that is more than 50 percent owned (directly, indirectly or constructively) by “U.

shareholder” of a controlled foreign corporation (CFC) is required to include in its gross income its pro rata share of a CFC’s “subpart F” income, regardless of whether such income is distributed.

Please see page 22 in the following publication under "liquidating distributions": distribution is from several companies, but I can't find the names.

I am dealing with a financial advisor representing a large investment company, and it is very hard to get any information from them. I would determine first if it is long or short term holding period.

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corporation (typically the parent of an affiliated group) becomes a wholly owned subsidiary of a foreign corporation (through a merger into the foreign corporation’s U. subsidiary) or transfers its assets to the foreign corporation, but at the same time keeps most of its operations in the United States. Continue Reading Converting Subpart F Income into Qualified Dividends U. shareholders of foreign corporations are generally not subject to tax on the earnings of such corporations until the earnings are repatriated to the shareholders in the form of a dividend. Unless an applicable income tax treaty applies to reduce the rate of tax, FDAP income typically will be subject to a 30 percent gross basis …If you bought more than one block of stock, you will need to figure it out based on the instructions provided.If there is no capital gain or loss (distribution and basis the same), you do not need to report it but you may choose to, by listing it on Schedule D with no gain or loss.I would use the date that the liquidation was done.

You should have this somewhere on a statement or a check if you received cash. subsidiaries being recently stepped up to fair market value pursuant to the check-the-box election, there will be no “gain” in the reorganization.