Treasury Regulations · 26 CFR
§ 1.1502-34. Special aggregate stock ownership rules.
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. § 1502
Cite as 26 CFR § 1.1502-34
At a glance
Read from the text and its source citation. Not part of the regulation.
- Status
- In the current eCFR
- Issued
- December 30, 2024 by T.D. 10018
- Issued under
- 26 U.S.C. § 1502
- Length
- 301 words · about 1 min to read
- Cross-references
- cites 3 Code sections and 0 regulations; cited by 6
¶(a) Determination of stock ownership. For purposes of the consolidated return regulations, in determining the stock ownership of a member of a group in another corporation (issuing corporation) for purposes of determining the application of section 165(g)(3)(A), 332(b)(1), 351(a), 732(f), or 904(f) in a consolidated return year, stock in the issuing corporation owned by all other members of the group is included. For the determination of whether a member of the group is an 80-percent distributee, see section 337(c) (providing that, for purposes of section 337, the determination of whether any corporation is an 80-percent distributee is made without regard to any consolidated return regulation).
¶(b) Example regarding liquidation of member. The following example illustrates the stock ownership aggregation rule set forth in paragraph (a) of this section.
¶(1) Facts. P wholly owns A, B, and C, each of which is a member of the P group. A, B, and C each owns 33 1/3 percent of the stock of D. D liquidates in a transaction purported to qualify under section 332.
¶(2) Analysis. For purposes of determining satisfaction of the 80-percent stock ownership requirement under section 332(b)(1), under the stock ownership aggregation rule set forth in paragraph (a) of this section: A is treated as owning all of the D stock owned by B and C; B is treated as owning all of the D stock owned by A and C; and C is treated as owning all of the D stock owned by A and B. Therefore, each of A, B, and C is treated as owning 100 percent of the stock of D and thus meeting the 80-percent stock ownership requirement for purposes of section 332. However, none of A, B, or C is treated as an 80-percent distributee for purposes of section 337. See section 337(c). Therefore, section 337(a) does not apply.
[T.D. 10018, 89 FR 106871, Dec. 30, 2024]
Cross-references
Computed from the citations in the text of 26 CFR.
Code sections it cites
- § 165 Losses
- § 337 Nonrecognition for property distributed to parent in complete liquidation of subsidiary
- § 332 Complete liquidations of subsidiaries
Cited by 6 other regulations
- § 1.108(i)-1 Deferred discharge of indebtedness income and deferred original issue discount deductions of C corporations.
- § 1.336-2 Availability, mechanics, and consequences of section 336(e) election.
- § 1.355-8 Definition of predecessor and successor and limitations on gain recognition under section 355(e) and section 355(f).
- § 1.732-3 Corresponding adjustment to basis of assets of a distributed corporation controlled by a corporate partner.
- § 1.1502-13 Intercompany transactions.
- § 1.1502-80 Applicability of other provisions of law.
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. 10018 (89 FR 106871)
Where it sits in 26 CFR
- Subchapter A Income tax
- Part 1 Income taxes
- Basis, Stock Ownership, and Earnings and Profits Rules
Nearby sections
- § 1.1502-30 Stock basis after certain triangular reorganizations.
- § 1.1502-31 Stock basis after a group structure change.
- § 1.1502-32 Investment adjustments.
- § 1.1502-33 Earnings and profits.
- § 1.1502-34 Special aggregate stock ownership rules.
- § 1.1502-35 Transfers of subsidiary stock and deconsolidations of subsidiaries.
- § 1.1502-36 Unified loss rule.