4 Redemptions and Partial Liquidations

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Lyrics

[Verse 1]
When shareholders sell stock back to their corp
Four safe harbors keep them from getting scorched
Not essentially equivalent means the deck reshuffles clean
Substantially disproportionate cuts your slice by eighty percent
Complete termination wipes your ownership slate
Partial liquidation shrinks the corporate state

[Chorus]
Three-oh-two redemptions, four paths to walk through
Not equivalent, disproportionate, complete termination too
Partial liquidation makes the fourth way clear
Attribution rules decide what shares appear
Section three-oh-two, section three-oh-two
Four redemptions waiting there for you

[Verse 2]
Attribution rules from three-one-eight decree
Family shares count as yours, no secrecy
Spouse and children, parents in the mix
Grandchildren's holdings in your numbers stick
But family waiver breaks these binding chains
If you sever ties, independence gains

[Chorus]
Three-oh-two redemptions, four paths to walk through
Not equivalent, disproportionate, complete termination too
Partial liquidation makes the fourth way clear
Attribution rules decide what shares appear
Section three-oh-two, section three-oh-two
Four redemptions waiting there for you

[Bridge]
When redemptions fail the qualifying test
Three-oh-one distribution becomes your guest
Dividend treatment hits your income hard
Capital gains treatment throws away its card

[Verse 3]
Three-oh-three redemption serves a special need
Estate tax payments make the heirs plead
Corporate stock gets sold to pay the bill
Death and taxes climbing up the hill
This narrow exception breaks the general rule
Estate planning's most essential tool

[Chorus]
Three-oh-two redemptions, four paths to walk through
Not equivalent, disproportionate, complete termination too
Partial liquidation makes the fourth way clear
Attribution rules decide what shares appear
Section three-oh-two, section three-oh-two
Four redemptions waiting there for you

[Outro]
Four safe harbors in the tax code sea
Redemptions sailing toward prosperity
Know your options when the shares come home
Navigate the rules, don't sail alone

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