The draconian income tax outcomes for corporate liquidations, especially for C corporations, have boosted the popularity of corporate reorganizations1 as an alternative planning strategy.2 Indeed, it is about the only strategy that can be accomplished with little or no income tax liability to separate warring factions in C or S corporations or to simply address the reality that shareholders in a corporation would prefer to be in sole charge of the management of their shares of the assets.
Harl, Neil E.
"Consequences of Divisive, Type D, Reorganizations for S Corporations,"
Agricultural Law Digest: Vol. 22
, Article 1.
Available at: https://lib.dr.iastate.edu/aglawdigest/vol22/iss4/1