The subsidiary does not recognize gain on the distribution of any appreciated assets to the parent, which is an exception to the general rule of Section 311(b) that treats a corporate distribution of appreciated assets as a sale.
"(ii) reasonable alternatives to the action with adverse energy effects and the expected effects of such alternatives on energy supply, distribution, and use" (Sec. 2(b)).
An example is in order: You have an IRA at Mutual Fund Company A, and you take a rollover distribution, and you deposit the money into your IRA account at Brokerage B.
Corporations with the capacity to distribute dividends should consider making a distribution in 2012 before the: (a) Medicare tax kicks in and (b) tax rate potentially increases from 15% to 39.6%.