Reg. § 1.332-1 Distributions in liquidation of subsidiary corporation; general.
Under the general rule prescribed by section for the treatment of distributions in liquidation of a corporation, amounts received by one corporation in complete liquidation of another corporation are treated as in full payment in exchange for stock in such other corporation, and gain or loss from the receipt of such amounts is to be determined as provided in section . Section excepts from the general rule property received, under certain specifically described circumstances, by one corporation as a distribution in complete liquidation of the stock of another corporation and provides for the nonrecognition of gain or loss in those cases which meet the statutory requirements. Section places a limitation on the application of section in the case of foreign corporations. See section for the basis for determining gain or loss from the subsequent sale of property received upon complete liquidations such as described in this section. See section relative to distribution of installment obligations by subsidiary.