5 Complete Liquidations

US Tax Code Essentials · 3:29

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Lyrics

[Verse 1]
When a company decides to close its doors
Section three three one tells us what's in store
Shareholders get cash or property in hand
Treat it like a sale across the land
Take your basis out, the rest is gain
Capital treatment, that's the refrain

[Chorus]
Three three one for shareholders, gain or loss
Three three six, the corp pays the cost
Three three two and seven, eighty percent
Subsidiary liquidation, tax event prevented
Five complete ways liquidation plays
Know the rules for corporate ending days

[Verse 2]
Three three six says the corporation
Must recognize gains across the nation
When assets go out at fair market price
Versus basis, roll the tax dice
Losses too get recognized
Unless exceptions are applied

[Chorus]
Three three one for shareholders, gain or loss
Three three six, the corp pays the cost
Three three two and seven, eighty percent
Subsidiary liquidation, tax event prevented
Five complete ways liquidation plays
Know the rules for corporate ending days

[Verse 3]
Eighty percent or more ownership stake
Three three two makes the earth shake
Parent gets the assets, no gain to see
Three three seven keeps the corp tax free
Subsidiary melts into the parent's frame
Tax-free liquidation is the name of the game

[Bridge]
But watch out for the reincorporation trick
Courts will catch it, make the taxes stick
Liquidate and then reform too soon
They'll collapse it under common tune
Substance over form will always win
Don't let form games make your head spin

[Chorus]
Three three one for shareholders, gain or loss
Three three six, the corp pays the cost
Three three two and seven, eighty percent
Subsidiary liquidation, tax event prevented
Five complete ways liquidation plays
Know the rules for corporate ending days

[Outro]
Complete liquidations, five rules to know
Tax consequences, watch the money flow
From shareholder pockets to corporate halls
Remember these sections when liquidation calls

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