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Situational Chart of Rev. Rul. 78-401 - No Meaningful Reduction In The Shareholder's Proportionate Interest

2013-08-24

Below is a chart of Rev. Rul. 78-401 in which the IRS held that a stock redemption which reduced the majority shareholder's interest from 90% down to 60% was not essentially equivalent to a dividend as defined in Code §302(b) because there was not a "meaningful reduction in the shareholder's proportionate interest." Consequently, the redemption was treated as a Code §301 distribution (typically a dividend) and was not treated as a sale or exchange.

The chart can be viewed as a PDF file here: Rev. Rul. 78-401

For additional details regarding distributions in redemption of stock, see our Section 302 Flowchart.

International Tax Blog - New and Interesting International Tax Issues

Situational Chart of Rev. Rul. 78-401 - No Meaningful Reduction In The Shareholder's Proportionate Interest

Tags: Charts - Situational Charts

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