Treasury Regulations · 26 CFR
§ 1.1059(e)-1. Non-pro rata redemptions.
Regulation text, no changes From the eCFR, current as of October 15, 2026. The eCFR is an authoritative but unofficial editorial compilation of the Code of Federal Regulations; the official text is the annual CFR on govinfo. Compare it with this section on ecfr.gov (external site) or the official annual CFR on govinfo (external site).
Regulation under 26 U.S.C. § 1059(e)
Cite as 26 CFR § 1.1059(e)-1
At a glance
Read from the text and its source citation. Not part of the regulation.
- Status
- In the current eCFR
- Issued
- July 16, 1997 by T.D. 8724
- Issued under
- 26 U.S.C. § 1059(e)
- Length
- 151 words · about 1 min to read
- Cross-references
- cites 3 Code sections and 0 regulations; cited by 0
¶(a) In general. Section 1059(d)(6) (exception where stock held during entire existence of corporation) and section 1059(e)(2) (qualifying dividends) do not apply to any distribution treated as an extraordinary dividend under section 1059(e)(1). For example, if a redemption of stock is not pro rata as to all shareholders, any amount treated as a dividend under section 301 is treated as an extraordinary dividend regardless of whether the dividend is a qualifying dividend.
¶(b) Reorganizations. For purposes of section 1059(e)(1), any exchange under section 356 is treated as a redemption and, to the extent any amount is treated as a dividend under section 356(a)(2), it is treated as a dividend under section 301.
¶(c) Effective date. This section applies to distributions announced (within the meaning of section 1059(d)(5)) on or after June 17, 1996.
[T.D. 8724, 62 FR 38028, July 16, 1997]
Cross-references
Computed from the citations in the text of 26 CFR.
Code sections it cites
Amendment history
From the source citation at the end of the section, newest first. T.D. is a Treasury decision; FR is the Federal Register.
- Issued by T.D. 8724 (62 FR 38028)
Where it sits in 26 CFR
- Subchapter A Income tax
- Part 1 Income taxes
- Special Rules
Nearby sections
- § 1.1055-1 General rule with respect to redeemable ground rents.
- § 1.1055-2 Determination of amount realized on the transfer of the right to hold real property subject to liabilities under a redeemable ground rent.
- § 1.1055-3 Basis of real property held subject to liabilities under a redeemable ground rent.
- § 1.1055-4 Basis of redeemable ground rent reserved or created in connection with transfers of real property before April 11, 1963.
- § 1.1059(e)-1 Non-pro rata redemptions.
- § 1.1059A-1 Limitation on taxpayer's basis or inventory cost in property imported from related persons.
- § 1.1060-1 Special allocation rules for certain asset acquisitions.
- § 1.1061-0 Table of contents.
- § 1.1061-1 Section 1061 definitions.