453 d and liquidating
The election would apply to all liquidating distributions only to that shareholder. Installment Treatment by the Corporation So far, we have been talking solely about installment treatment to the distributee shareholders.Separate elections cannot be made for separate blocks of stock. Now, let's refer to a corporation's use of the installment method itself.CAN YOU USE THE INSTALLMENT METHOD ON CORPORATE LIQUIDATIONS By Robert W.
Section 453(h) allows a shareholder who receives certain installment notes in exchange for stock in a Section 331 liquidation to treat the receipt of the payments under the note (rather than the receipt of the note) as payment for the stock.
Of course, this doesn't ameliorate the sting of General Utilities repeal.
The C corporation will presumably still pay tax on its distribution of assets.
A "qualifying installment obligation" is any one of the following: What is a qualifying shareholder?
This is simply a shareholder as to which Section 331 applies to the liquidating distribution.