Liquidating qsss qsub
Much of the popularity of spin-offs, especially when the alternative is a simple divestiture (selling part of a corporations operations to a third party), can be traced to a companys ability to structure the transaction so it is tax-free.
Additionally, as stated in TIR 03-20, which explains St. 4, § 18, any QSUB that is not subject to the financial institution excise under G.
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This change in policy will be applied prospectively from July 1, 2004. Credit and net operating loss carryovers incurred by the QSUB before the reorganization can be used, as applicable, to offset the financial institution's tax liability.
To the extent that the Department's past public written statements have stated otherwise, this Directive reaffirms the rule that the corporate non-recognition provisions of the Code that apply to corporate trusts are limited to those set forth in §§ 351-368. Thus, it must file Form 63FI, not Form 355S, as stated in Directive 3. In computing its net income subject to tax under § 2 for the taxable year in which the reorganization takes place, the financial institution should do so based solely on its own items of income, loss, deduction, and credit.