26 USC 997
26 USC 997
§ 997 - Special subchapter C rules
CHAPTER 1— NORMAL TAXES AND SURTAXES › Subchapter N— Tax Based on Income From Sources Within or Without the United States
For purposes of applying the provisions of subchapter C of chapter 1, any distribution in property to a corporation by a DISC or former DISC which is made out of previously taxed income or accumulated DISC income shall—
(1) be treated as a distribution in the same amount as if such distribution of property were made to an individual, and
(2) have a basis, in the hands of the recipient corporation, equal to the amount determined under paragraph (1).