§997 — Special subchapter C rules
1 citing cases
Statute Text — 26 U.S.C. §997
For purposes of applying the provisions of subchapter C of chapter 1, any distribution in property to a corporation by a DISC or former DISC which is made out of previously taxed income or accumulated DISC income shall—
be treated as a distribution in the same amount as if such distribution of property were made to an individual, and
have a basis, in the hands of the recipient corporation, equal to the amount determined under paragraph (1).
Treasury Regulations
-
Treas. Reg. §1.997-1Special rules for subchapter C of the Code
(a) For purposes of applying the provisions of sections 301 through 395 of the Code, any distribution in property to a corporation by a DISC, or former DISC, which is made out of previously taxed income or accumulated DISC income shall be treated as a distribution in the same amount as if such distribution of property were made to an individual, and have a basis, in the hands of the recipient corporation, equal to such amount treated as having been distributed.
(b) This section may be illustrated by the following example:
-
Treas. Reg. §1.997-1(a)For purposes of applying the provisions of sections 301 through 395 of the Code, any distribution in property to a corporation by a DISC, or former DISC, which is made out of previously taxed income or accumulated DISC income shall be treated as a distribution in the same amount as if such distribution of property were made to an individual, and have a basis, in the hands of the recipient corporation, equal to such amount treated as having been distributed.
For purposes of applying the provisions of sections 301 through 395 of the Code, any distribution in property to a corporation by a DISC, or former DISC, which is made out of previously taxed income or accumulated DISC income shall be treated as a distribution in the same amount as if such distribution of property were made to an individual, and have a basis, in the hands of the recipient corporation, equal to such amount treated as having been distributed.
-
Treas. Reg. §1.997-1(b)§1.997-1(b)
This section may be illustrated by the following example:
1 Citing Cases
- 10 - October 3, 2003.5 The executors also elected under New York Tax Law section 997 (McKinney 1999) to pay New York estate tax in 10 annual installments.