Subchapter C
E65992
Subchapter C is the section of the U.S. tax code that governs the federal income taxation of corporations and their shareholders, including rules on corporate formations, operations, distributions, and reorganizations.
All labels observed (2)
| Label | Occurrences |
|---|---|
| Subchapter C canonical | 4 |
| Subchapter C of the Internal Revenue Code | 1 |
How this entity was disambiguated
This entity first appeared as the object of triple T527164 — resolving that mention is where its identity was fixed. The disambiguator weighed these candidate entities and picked the highlighted one (or “None”, minting a new entity). This is how homonymy is resolved: the same surface form can point to different entities.
NED1
Entity disambiguation (via context triple)
gpt-5-mini-2025-08-07
Target entity: Subchapter C Context triple: [Internal Revenue Code, contains, Subchapter C]
-
A.
Subchapter S
Subchapter S is the section of U.S. tax law that governs S corporations, allowing certain closely held corporations to pass corporate income, losses, deductions, and credits through to their shareholders for federal tax purposes.
-
B.
Subtitle C
Subtitle C is the portion of the Resource Conservation and Recovery Act that establishes the federal regulatory framework for managing hazardous waste from its generation through its final disposal.
-
C.
Section of Taxation
The Section of Taxation is the American Bar Association’s primary professional group for lawyers and other practitioners specializing in federal, state, and local tax law.
-
D.
Tax Division
The Tax Division is a component of the U.S. Department of Justice responsible for enforcing federal tax laws and handling civil and criminal tax litigation on behalf of the United States.
-
E.
Internal Revenue Code
The Internal Revenue Code is the comprehensive body of federal tax law in the United States that governs the assessment and collection of most national taxes.
- F. None of above. chosen
- G. Unsure - the case is ambiguous/there is not enough information to decide.
NED2
Entity disambiguation (via description)
gpt-5-mini-2025-08-07
Target entity: Subchapter C Target entity description: Subchapter C is the section of the U.S. tax code that governs the federal income taxation of corporations and their shareholders, including rules on corporate formations, operations, distributions, and reorganizations.
-
A.
Subchapter S
Subchapter S is the section of U.S. tax law that governs S corporations, allowing certain closely held corporations to pass corporate income, losses, deductions, and credits through to their shareholders for federal tax purposes.
-
B.
Subtitle C
Subtitle C is the portion of the Resource Conservation and Recovery Act that establishes the federal regulatory framework for managing hazardous waste from its generation through its final disposal.
-
C.
Section of Taxation
The Section of Taxation is the American Bar Association’s primary professional group for lawyers and other practitioners specializing in federal, state, and local tax law.
-
D.
Tax Division
The Tax Division is a component of the U.S. Department of Justice responsible for enforcing federal tax laws and handling civil and criminal tax litigation on behalf of the United States.
-
E.
Internal Revenue Code
The Internal Revenue Code is the comprehensive body of federal tax law in the United States that governs the assessment and collection of most national taxes.
- F. None of above. chosen
Statements (48)
| Predicate | Object |
|---|---|
| instanceOf |
U.S. federal tax law regime
ⓘ
section of the U.S. Internal Revenue Code ⓘ |
| appliesTo |
C corporations
ⓘ
certain foreign corporations with U.S. connections ⓘ corporate shareholders ⓘ domestic corporations ⓘ |
| covers |
corporate distributions
ⓘ
corporate formations ⓘ corporate liquidations ⓘ corporate operations ⓘ corporate reorganizations ⓘ |
| distinguishedFrom |
Subchapter K
ⓘ
Subchapter S ⓘ |
| governs |
federal income taxation of corporate shareholders
ⓘ
federal income taxation of corporations ⓘ |
| hasConcept |
basis rules for stock and property
ⓘ
boot in reorganizations and exchanges ⓘ carryovers of tax attributes in reorganizations ⓘ complete liquidations ⓘ control requirement in corporate formations ⓘ corporate-level gain recognition ⓘ distributions of appreciated property ⓘ dividends ⓘ double taxation of corporate income ⓘ earnings and profits ⓘ nonrecognition of gain or loss in certain transactions ⓘ partial liquidations ⓘ plan of reorganization requirement ⓘ redemptions of stock ⓘ reorganization continuity of business enterprise ⓘ reorganization continuity of interest ⓘ shareholder-level gain recognition ⓘ step transaction doctrine (as applied to corporate transactions) ⓘ tax treatment of stock dividends ⓘ tax treatment of stock rights ⓘ tax-free reorganizations ⓘ |
| jurisdiction |
United States of America
ⓘ
surface form:
United States
|
| legalArea |
corporate income tax
ⓘ
shareholder-level income tax ⓘ |
| objective |
define when corporate transactions are taxable or tax-free
ⓘ
prevent tax avoidance through corporate transactions ⓘ |
| partOf |
Internal Revenue Code
ⓘ
surface form:
Internal Revenue Code of 1986
|
| regulates |
tax consequences of corporate acquisitions
ⓘ
tax consequences of corporate divisive reorganizations ⓘ tax consequences of corporate mergers ⓘ tax consequences of corporate recapitalizations ⓘ |
| taxTreatment |
corporation taxed as separate entity from shareholders
ⓘ
shareholders taxed on dividends and certain distributions ⓘ |
How these facts were elicited
The pipeline generated the facts above by prompting gpt-5.1 with this entity's name + description and the instruction below.
Instruction
You are a knowledge base construction expert. Given a subject entity and a description of it, return factual statements that you know for the subject as a JSON list of dictionaries(triples), where keys must be "subject", "predicate" and "object". The number of facts may be very high, between 25 to 50 or more, for very popular subjects. For less popular subjects, the number of facts can be very low, like 5 or 10. # Requirements - If you don't know the subject at all, return an empty list. - If the subject is not a named entity, return an empty list. - Include at least one triple where predicate is "instanceOf". - Do not get too wordy. - Separate several objects into multiple triples with one object.
Input
Subject: Subchapter C Description of subject: Subchapter C is the section of the U.S. tax code that governs the federal income taxation of corporations and their shareholders, including rules on corporate formations, operations, distributions, and reorganizations.
Referenced by (5)
Full triples — surface form annotated when it differs from this entity's canonical label.
this entity surface form:
Subchapter C of the Internal Revenue Code