Summary Description of Revenue Reconciliation Provisions for Finance Committee Consideration Jcx-17-87

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A personal service corporation is a corporation substantially all the activities of which involve the performance of services in the fields of health, law, engineering, architecture, accounting, actuarial science, performing arts, or consulting, and substantially all the stock of which is held by the employees performing services for the corporation.
Effective Date The provision would apply to taxable years beginning after December 31, 1987.
-12- 4. Liquidation of Corporate Subsidiaries Present
... Law Gains on certain distributions to a controlling corporate shareholder (an 80-percent distributee) are not taxed to the distributing corporation in a liquidation. By contrast, a nonliquidating distribution to such a shareholder causes the distributing corporation to recognize gain, though if the two corporations were filing consolidated returns the gain would be deferred until a disposition of the distributed property or certain other events. Certain divisive distributions of corporate stock are also tax-free to the distributing corporation.

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