Page 779 - Large Business IRS Training Guides

E&P
Reduction Transactions &

Specified Transactions (cont’d)

transaction is treated per se as being undertaken with a
• A specified
purpose of changing the amount of a section 965 element of
principal
shareholder.
a U.S.

• A specified transaction means an E&P reduction transaction that
involves
one or more of the following:

• A complete liquidation of an SFC to which section 331 applies;

• A sale or other disposition of stock by an SFC; or

• A distribution by an SFC that reduces the E&P of the SFC
to section 312(a)(3).
pursuant

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