Rev. Rul. 75-512 - Redemption Not Equivalent to a Dividend Under 302(b)(1)

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Rev. Rul. 75-512 - Redemption Not Equivalent to a Dividend Under 302(b)(1)

2024-10-20

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Today we published a chart of Rev. Rul. 75-512.

Rev. Rul. 75-512 concludes that a redemption of shares owned by a trust was treated as a sale or exchange under section 302(b)(1), even though it did not meet the safe harbors under sections 302(b)(2) or 302(b)(3). The ruling is a reminder that family attribution under section 318(a)(1)(A) does not apply to attribute shares to in-laws or to grandchildren. [Although section 318(a)(1)(A) attributes shares from grandchildren to grandparents, it does not attribute shares from grandparents to grandchildren.]

International Tax Blog - New and Interesting International Tax Issues

Rev. Rul. 75-512 - Redemption Not Equivalent to a Dividend Under 302(b)(1)

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