In In re East End Development, LLC, 2013 WL 1820182 (Bankr. E.D.N.Y. Apr.
You will rely on section 355 for nonrecognition, but here you also must rely on section 332 to make the liquidations tax free, without any liquidation-reincorporation problem. It's very clear that you can get the results you want, but not clear why.
LTR 201123022 describes these facts, in simplified form:
Yesterday, the European Commission announced that it was termporarily approving, under E.U.
On Friday, the Illinois Department of Financial and Professional Regulation, Division of Banking closed Ravenswood Bank, headquartered in Chicago, Illinois, and appointed the FDIC as receiver for the bank.
Yesterday, the Special Inspector General for the Trouble Asset Relief Program (SIGTARP) released a report criticizing the Treasury Department’s role in the accelerated closure of hundreds of GM and Chrysler dealerships.
On Friday, the Nevada Financial Institutions Division closed Sun West Bank, headquartered in Law Vegas, Nevada, and appointed the FDIC as receiver. As receiver, the FDIC entered into a purchase and assumption agreement with City National Bank, headquartered in Los Angeles, California, to assume all of the deposits of the failed bank.
Yesterday, the Office of the Commissioner of Financial Institutions of the Commonwealth of Puerto Rico closed R-G Premier Bank of Puerto Rico, headquartered in Hato Rey, Puerto Rico, and the FDIC was appointed receiver.
On Friday, the Illinois Department of Financial Professional Regulation – Division of Banking closed Bank of Illinois, headquartered in Normal, Illinois, and the FDIC was named receiver.
On Friday, the Washington Department of Financial Institutions closed American Marine Bank, headquartered in Bainbridge Island, Washington, and the FDIC was named receiver.