Rev. Rul. 55-312

Section 902(d) of the Internal Revenue Code of 1954 provides for the treatment to be accorded specified distributions of property received by a domestic corporation from a wholly-owned foreign corporation, in lieu of the general treatment of property distributions as provided for in section 301 of the Code. The term `property' as used in section 301 is defined in section 317(a) of the Code as specifically including `money.' Consequently, the term `property' as used in section 902(d) of the Code is deemed to include `money.