Liquidating corporation liabilities Adult vedio chat with arbi girls
Instead, it is treated as if incorporation had never occurred, with the felicitous result that the tax consequences that ordinarily attend a corporate liquidation (as depicted in Section 336(a) and Section 331(a), supra) are avoided.
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Further, while the corporation could first convert into a partnership and then into an LLC, it would incur greater expense than if the corporation converted directly into an LLC.
Moreover, the IRS pointed out that the proposed transaction would be completed by the end of the 2009 taxable year, which would be within the same taxable year as the conversion of the partnership into a corporation.
It was represented that there is no material difference in the ultimate economic outcome and tax consequences between the two-step conversion (from a corporation to a partnership and then to an LLC) and the one-step conversion (from a corporation to an LLC) that was to be undertaken in this case.
Bankrupt businesses liquidate for several reasons; one is that stakeholders in the business, meaning its creditors and investors, cannot come to an agreement on how the business should restructure itself under Chapter 11 to restore its profitability.
Another is when a business cannot restore its profitability and any attempt at restructuring is doomed to failure.