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September 7, 2022
2022-1339

Chief Counsel memo addresses best practices for reviewing multi-year IRC Section 332 liquidations

An IRS Chief Counsel memorandum (AM 2022-002, September 2, 2022) discusses best practices for reviewing multi-year IRC Section 332 liquidations. Also, an appendix attached to the memorandum describes: (1) the tax consequences of a complete liquidation qualifying under IRC Section 332; (2) rules applicable to corporate subsidiaries intending to accomplish multi-year liquidations under IRC Sections 332(b) and 337(a); and (3) the tax consequences of a complete liquidation that fails to qualify under IRC Section 332. A Tax Alert is forthcoming.

 

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