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Under Revenue Procedure 82-58, the IRS will issue a private letter ruling if 8 conditions are met.Such conditions include, among other things, that the primary purpose of the trust is liquidation of the assets with no objective of carrying on a trade or business and the trust agreement should contain a fixed or determinable termination date. A "business trust" should be considered instead of a liquidating trust if the purpose of the trust is to carry on a trade or business.A liquidating trust may also be an effective method for a fund manager to wind down a fund without having a significant role in the liquidation.At the end of the fund's life cycle or term, the fund manager may have certain assets that are not easily liquidated and convertible into cash for distribution to the owners of the fund.
Thus, the partner's basis in the property can never be greater than the partner's basis in the partnership.
A business trust is either treated as a corporation or partnership for federal income tax purposes.
Since the business assets are deemed to have been distributed to the owners and then transferred to the liquidating trust, there will be an immediate recognition of a gain or loss from liquidation of the former business by the owners.
The trust will be considered a liquidating trust with the primary purpose of liquidating its assets.
Should the purpose of the entity change, such as to carry on a for-profit business, then the entity will no longer be considered a liquidating trust.
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This reserve could be held in the trust for any contingent liabilities as they become due.