On July 6, the company was placed in receivership for the purpose of liquidation
by the Circuit Court of Leon County, Florida.
are the location and timing of gain on the NB asset, the reformation of T's stock basis and the separation of E&P from the business that generated such earnings.
305 regulations do not elaborate on how much of a right to earnings and liquidation
351 transfer is followed, as part of the plan, by a liquidation
of the transferred corporation, applicable Federal tax principles convert the stock transfer to an asset reorganization.
Finally, the court agreed with the taxpayers and held that the liquidation
provisions comprising the agreements were not "applicable restrictions" based on the exception contained in Sec.
If a PFIC intends to liquidate, but fails to observe the necessary formalities for liquidation
, a U.
The deemed sale of assets and deemed liquidation
is that of old target.