The overreaction hypothesis, as postulated by De Bondt and Thaler , dictates that stocks that have performed poorly in the past (low liquidate stocks) tend to outperform stocks that have performed well in the past (high liquidate stocks).
Stocks with poor past returns (low liquidate stocks) outperformed those with relatively well past performance (high liquidate stocks).
In 1963, the company decided to liquidate
. It sold its properties, including the leases, in that year and went out of business.
However, if SJ sells substantially all of its assets, retains the proceeds without purchasing new assets and does not liquidate
, it could be deemed a personal holding company (PHC) subject to the PHC tax.
When HexMyst liquidates
in 2005, the distribution rule applies.
Following the exchange, the target liquidates, distributing the acquirer's voting stock and cash to the individual.
After T transfers all of its assets, it liquidates, distributing the A stock and cash to I.
721 transactions, then liquidates. A and B are the partners of both A1B1 and A2B2.
BC liquidates, distributing the AB interests and the cash to B and C.
From a practical perspective, C and D reorganizations are probably not viable alternatives, because they require an owner of a disregarded entity to transfer substantially all of its assets to the acquirer, leaving the owner to liquidate
and distribute its assets to its shareholders.
When an S corporation liquidates, all of its tax attributes (including accumulated adjustments account (AAA), C corporation net operating losses (NOLs), suspended losses and adjusted earnings and profits (AE&P)) disappear.
When a corporation plans to liquidate, Form 966, Corporate Dissolution or Liquidation, should be filed, as well as appropriate Forms 1099-DIV, Statement for Recipients of Dividends and Distributions, and 1096, Annual Summary end transmittal of U.S.
This change can result in a "whip-saw" to a QSST (and its beneficiary) when the S corporation sells its assets and then liquidates, rather than selling the stock directly.
This problem might be avoided if the trustee has the authority to liquidate the trust and pass the loss to the beneficiary under Regs.