At first glance, the rules for a complete liquidation
of a partner's interest appear simple.
Ultimately, partial liquidations
suffered the ignominy of the repeal of section 346 and the enactment of a subsection in the redemption rules (section 302(b)(4)).
Under IRC section 302(b)(4), two requirements for partial liquidation
By resolution type, real estate owned (REO) liquidations
generally have the highest loss severity.
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.
Accordingly, transactions such as liquidations
, redemptions, distributions, and contributions are addressed in Treas.
corporations to foreign persons in certain otherwise tax-free spin-offs, split-ups, split-offs and liquidations
of controlled subsidiaries.
The firm, which is managing two of the largest retail liquidations
now underway - Tower Records and Storehouse - noted that the Boston location will strengthen its ability to serve the growing market for retail asset disposition.
com to remarket and sell our obsolete and discontinued products, we have realized higher returns, faster turnaround and tremendous efficiencies in the reverse supply chain," said Joseph Scarpantonio, Manager, Inventory Liquidations
and Kristin Waltz, Inventory Exit Coordinator.
We are very humbled while being delighted at the tremendous growth that UAB Liquidations
is experiencing throughout the world," said Ray Whitmer, CEO.
offers manufacturers, wholesalers, distributors, and retailers with the most effective option for the sale and liquidation
of closeout and discontinued merchandise and equipment.
United Auction Brokers(TM), LLC, the parent company of UAB Liquidations
(TM) and UAB Closeouts(TM), announced today plans to open 50 new offices in major markets to serve the exploding demand for their liquidation
and sales services.