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Update to Classification of Transactions Chart (Waterman Steamship, etc.)

2026-03-07

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Today we updated our Classification of Transactions chart to include cases distinguishing whether pre-sale dividends should be respected as dividends or treated as sales proceeds. Some of the cases for this category include:

Steel Improvement v. Commr., 36 T.C. 265 (1961) (a pre-sale dividend was treated as sales proceeds)
TSN Liquidating v. U.S., 624 F.2d 1328 (5th Cir. 1980) (a pre-sale dividend was respected as a dividend)
Uniroyal v. Commr., T.C. Memo. 1993-214 (a pre-sale dividend was respected as a dividend)
Waterman Steamship v. Commr., 430 F.2d 1185 (5th Cir. 1970) (a pre-sale dividend was treated as sales proceeds)

International Tax Blog - New and Interesting International Tax Issues

Update to Classification of Transactions Chart (Waterman Steamship, etc.)

Tags: 861 Source of Income, Charts - Situational Charts

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