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31, 2017, and its Statutory Income statement 2018 Preliminary (unaudited) report noted its policyholder surplus was a negative million as of Jan.

31, 2018, and after the company also failed to file its required yearly statutory statement.

Section 337 - Tax Consequences to Subsidiary (1) Subsidiary Not Taxable on Distributions to Parent with Respect to Stock (2) Subsidiary Not Taxable on Transfers in Satisfaction of Debt to Parent (3) Subsidiary Taxable on Certain Distributions to a Tax-Exempt Parent c. Basic Requirements of Nontaxable Subsidiary Liquidations A.

Section 332 - Tax Consequences to Parent (1) Parent's Receipt of Property with Respect to Stock Is Nontaxable (2) Parent's Receipt of Property in Satisfaction of Debt Is Taxable b. Section 334 - Shareholders’ Basis in Property Received in Liquidation II.

Under the March 13 liquidation order issued in a Travis County court, all policies not previously expired will be terminated as of April 12.

Covered claims on all Texas policies will be paid by the Texas Property and Casualty Insurance Guaranty Association.

The Portfolio highlights traps for unwary taxpayers and discusses planning opportunities in connection with a corporate liquidation.

The Portfolio identifies issues arising in the context of deemed liquidations, and the special problems that can occur as a result of the interplay of the liquidation provisions with the S corporation rules and the consolidated return regulations.

Finally, the Portfolio reviews the issues arising from the liquidation of insolvent subsidiaries and the existence of intercorporate debt in subsidiary liquidations. Liquidations of Corporations Other than 80% Owned Corporate Subsidiaries a. Section 336 - Tax Consequences to the Liquidating Corporation c. Effect of Consolidated Return Rules on 80% Stock Ownership C. Exclusion of Stock which Is Limited and Preferred as to Dividends 4. Subsidiary Liquidations Not Qualifying Under § 332 A. Application of § 267(f) to Transfers in Satisfaction of Debt 3. Tax Consequences to Parent on Liquidation of Insolvent Subsidiary a. Qualification of an Insolvent Subsidiary for a Nontaxable Liquidation D. Determining Whether a Taxable Liquidation Is Advantageous 2. Consequences Before Liquidation if Parent Acquires Debt from Unrelated Party c. Consequences to Subsidiary of Repayment of Debt to Parent a.

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