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<h1>Amendment to Section 56: Tax-Neutral Transfers Between Wholly Owned Subsidiaries and Holding Companies Excluded from Income Taxation.</h1> Section 47 of the tax code provides for tax-neutral transfers, while Section 56 excludes income from certain tax-neutral transfers. However, transfers under clauses (iv) and (v) of Section 47 are not currently excluded from Section 56. To facilitate transactions between wholly owned subsidiaries and their holding companies, an amendment to Section 56 is proposed to exclude such transfers from its scope. This amendment is set to take effect on April 1, 2018, and will apply to transactions occurring on or after that date.
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