[Verse 1] When a parent holds the shares, ninety percent or more Section eighty-eight's the door to wind up and explore Subsidiary's got assets, time to liquidate But choose your pathway carefully, don't hesitate [Chorus] Eighty-eight one, eighty-eight two Different rules for me and you Bump-up basis, losses flow Wind-up rules you need to know Section eighty-eight, don't be late Tax elections seal your fate [Verse 2] Eighty-eight one is the choice when you want control Asset bump-ups to fair value, that's the goal But watch the capital gains, they'll hit the sub Before the assets transfer, that's the rub [Chorus] Eighty-eight one, eighty-eight two Different rules for me and you Bump-up basis, losses flow Wind-up rules you need to know Section eighty-eight, don't be late Tax elections seal your fate [Verse 3] Eighty-eight two's automatic, no election made Cost basis transfers over, price you paid But losses from the subsidiary can flow upstream To offset parent's income, living the dream [Bridge] Nine months to wind it down completely File the forms and do it neatly Non-capital losses carry forward Capital losses, different reward Choose your section, plan ahead Get the timing right instead [Chorus] Eighty-eight one, eighty-eight two Different rules for me and you Bump-up basis, losses flow Wind-up rules you need to know Section eighty-eight, don't be late Tax elections seal your fate [Outro] When the subsidiary's done its part Wind-up rules are quite an art Ninety percent ownership key Section eighty-eight sets you free
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