Recipient Corporation's Statement in an IRC Section 332 Liquidation

Summary

This form IRC Section 332 liquidation statement must be filed when a liquidating corporation distributes all of its assets in a liquidation intended to qualify under IRC Section 332. This template contains drafting notes and an alternate clause. The statement should be filed on or with the recipient corporation's income tax return for the applicable year. If the recipient corporation is a controlled foreign corporation, each U.S. shareholder must also include the statement on or with its return. In addition, the liquidation corporation should file an IRS Form 966 within 30 days from the date the corporation adopts a plan of liquidation and may be required to file IRS Form 952, as set forth in the template. The recipient corporation is also required to retain any permanent records and make them available to the IRS in support of the information provided in the statement. This information should include supporting documentation regarding the amount of all distributed property, the property's tax basis and fair market value, and any relevant facts regarding the liabilities assumed or extinguished as part of the liquidation.