The company was placed in liquidation
by the Leon County (Florida) Circuit Court on Jan.
Prior to liquidation
approval, AmeriVest provided Smart Space for Small Business[R] in Denver, Phoenix, and Dallas, through the acquisition, repositioning and operation of multi-tenant office buildings in those markets.
The application of the LR doctrine to an upstream C reorganization would be significant because, if an upstream combination of wholly owned T into P can constitute a C reorganization, many (if not most) liquidations
of T into P would be excepted from the LR doctrine.
It may be reasonably inferred that when, in addition to an instrument's fixed return, that instrument shares in at least 20% of the corporation's remaining earnings and liquidation
proceeds, and the corporation is likely to have earnings remaining after preferred distribution are made, that instrument should be viewed as participating in corporate growth to a significant extent for Sec.
If the check-the-box election is invalidated, in the example, there would be no deemed liquidation
of the transferred foreign corporation (A), the transaction would not be converted from an outbound stock transfer to a foreign-to-foreign asset reorganization, and P would be required to recognize gain, absent a GRA.
amount per share for the Series A-4-1 Preferred Shares and the Series A-4-2 Preferred Shares is $500,000, and there are 60 shares and 58 shares outstanding, respectively.
First, the IRS failed to recognize that a liquidation
occurred, presumably because the taxpayers did not observe the liquidation
In most cases, the transfer will be treated as a distribution in complete liquidation
to which Sec.
The $725,308 decrease in net assets in liquidation
from December 31, 2005 to June 30, 2006 is primarily attributable to the recording of a $4,226,938 provision upon the adoption by WRP's Board of Directors of modifications in the terms of WRP's stock option plans during the first quarter of 2006.
A corporation has more than one class of stock if all outstanding shares do not confer identical distribution and liquidation
announced that the United States Bankruptcy Court for the District of New Jersey has confirmed its Plan of Liquidation
Despite this change, courts still generally refused to allow a discount for taxes payable on liquidation