Taxation of liquidating distributions Remdom video chatnude girl
But what about distributions of the business’s intangible property and goodwill?
The Tax Court has held goodwill to be a vendible—and taxable—asset that can be sold with a professional practice 37 TC 39, 44 (1961)).
Such agreements can protect firms, the lawyers say.
THE CRITICAL ISSUE FOR TAX PLANNING is whether the assets distributed are considered property under IRC code section 336 and whether the corporation owns them.
This apparent contradiction presents some questions to which there are no black-and-white answers.
In the cases discussed in this article, the Tax Court did not distinguish between personal service corporations, such as CPA firms, and commercial organizations, such as an ice cream distribution company, in identifying the individual ownership of customer-based intangibles.
The critical issue for tax planning is whether the assets distributed are considered property under IRC section 336 and whether the corporation owns them.
In a professional practice, tangible property such as office equipment, furniture and fixtures makes up a small portion of a firm’s total value.