26 CFR § 1.1374-0 - Table of contents.

§ 1.1374-0 Table of contents.

This section lists the major paragraph headings for §§ 1.1374-1 through 1.1374-10.

§ 1.1374-1 General rules and definitions.

(a) Computation of tax.

(b) Anti-trafficking rules.

(c) Section 1374 attributes.

(d) Recognition period.

(e) Predecessor corporation.

§ 1.1374-2 Net recognized built-in gain.

In general.

Allocation rule.

Recognized built-in gain carryover.

Accounting methods.


§ 1.1374-3 Net unrealized built-in gain.

In general.


§ 1.1374-4 Recognized built-in gain or loss.

Sales and exchanges.

(1) In general.

(2) Oil and gas property.

(3) Examples.

Accrual method rule.

(1) Income items.

(2) Deduction items.

(3) Examples.

Section 267(a)(2) and 404(a)(5) deductions.

(1) Section 267(a)(2).

(2) Section 404(a)(5).

(3) Examples.

Section 481(a) adjustments.

(1) In general.

(2) Examples.

Section 995(b)(2) deemed distributions.

(f) Discharge of indebtedness and bad debts.

(g) Completion of contract.

(h) Installment method.

(1) In general.

(2) Limitation on amount subject to tax.

(3) Rollover rule.

(4) Use of losses and section 1374 attributes.

(5) Examples.

(i) Partnership interests.

(1) In general.

(2) Limitations.

(i) Partnership RBIG.

(ii) Partnership RBIL.

(3) Disposition of partnership interest.

(4) RBIG and RBIL limitations.

(i)-Sale of partnership interest.

(ii) Amounts of limitations.

(5) Small interest exception.

(i) In general.

(ii) Contributed assets.

(iii) Anti-abuse rule.

(6) Section 704(c) gain or loss.

(7) Disposition of distributed partnership asset.

(8) Examples.

§ 1.1374-5 Loss carryforwards.

In general.


§ 1.1374-6 Credits and credit carryforwards.

In general.



§ 1.1374-7 Inventory.


Identity of dispositions.

§ 1.1374-8 Section 1374(d)(8) transactions.

In general.

Effective date of section 1374(d)(8).

Separate determination of tax.

Taxable income limitation.


§ 1.1374-9 Anti-stuffing rule.
§ 1.1374-10 Effective date and additional rules.

In general.

Additional rules.

Certain transfers to partnerships.

Certain inventory dispositions.

Certain contributions of built-in loss assets.

(4) Certain installment sales.

(i) In general.

(ii) Examples.

Revocation and re-election of S corporation status.

In general.


[T.D. 8579, 59 FR 66463, Dec. 27, 1994, as amended by T.D. 9236, 70 FR 75731, Dec. 21, 2005]