Treasury Regulations · 26 CFR
§ 1.337-1. Nonrecognition for property distributed to parent in complete liquidation of subsidiary.
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. § 337
Cite as 26 CFR § 1.337-1
At a glance
Read from the text and its source citation. Not part of the regulation.
- Status
- In the current eCFR
- Issued
- March 28, 2016 by T.D. 9759
- Issued under
- 26 U.S.C. § 337
- Length
- 112 words · about 1 min to read
- Cross-references
- cites 4 Code sections and 1 regulation; cited by 0
¶(a) General rule. If sections 332(a) and 337 are applicable with respect to the receipt of a subsidiary`s property in complete liquidation, no gain or loss is recognized to the liquidating subsidiary with respect to such property (including property distributed with respect to indebtedness, see section 337(b)(1) and § 1.332-7), except as provided in section 337(b)(2) (distributions to certain tax-exempt distributees), section 367(e)(2) (distributions to foreign corporations), and section 897(d) (distributions of U.S. real property interests by foreign corporations).
¶(b) Applicability date. This section applies to any taxable year beginning on or after March 28, 2016.
[T.D. 9759, 81 FR 17074, Mar. 28, 2016]
Cross-references
Computed from the citations in the text of 26 CFR.
Code sections it cites
- § 332 Complete liquidations of subsidiaries
- § 337 Nonrecognition for property distributed to parent in complete liquidation of subsidiary
- § 367 Foreign corporations
- § 897 Disposition of investment in United States real property
Regulations 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. 9759 (81 FR 17074)
Where it sits in 26 CFR
- Subchapter A Income tax
- Part 1 Income taxes
- Effects on corporation
Nearby sections
- § 1.337-1 Nonrecognition for property distributed to parent in complete liquidation of subsidiary.
- § 1.337(d)-1 Transitional loss limitation rule.
- § 1.337(d)-2 Loss limitation rules.
- § 1.337(d)-3 Gain recognition upon certain partnership transactions involving a partner's stock.
- § 1.337(d)-4 Taxable to tax-exempt.