Further investigation of Subchapter K dissolves the facade of simplicity, as numerous parts of Subchapter K can come into play on a liquidation
of a partner's interest.
The section 346 regulations -- which continue to apply to partial liquidations
even though the statutory authority for partial liquidations
has been moved to section 302 -- provide that "active conduct" for this purpose will have the same meaning as it does under section 355.
That the redemption be in partial liquidation
within the meaning of section 302(e).
Even though loss severity by property type rose for many CMBS property types, the overall CMBS loss severity fell because of the high concentration of multifamily liquidations
in 2005; multifamily properties generally has the lowest loss severity by property type in CMBS.
The taxpayer-favorable effects of an LR transaction are significantly lessened if the shareholder is a corporation and the liquidation
, if respected, qualifies under Sec.
of Members previously Transferred in an Intercompany
In addition, new section 367(e)(2) regulations affect liquidations
under IRC section 332.
Hudson Capital's role in the liquidations
of Tower Records and Storehouse, which together have nearly 160 locations nationwide, demonstrates our team's capacity and expertise.
The UAB Liquidations
business model uniquely serves the interest of all clients in that we broker the sale of the client's inventory, seeking to obtain the absolute highest possible price for each item.
For more than 135 years United Auction Brokers(TM) has brokered the sale and liquidation
of everything from antiques to yachts using the services of their in-house brokers.
Many airline industry observers believe such a consolidation, whether through mergers or liquidations
, is needed to wring excess seat capacity out of the system, which, along with increased competition, has driven domestic air fares to historical lows and contributed to the industry's sustained weak financial performance.
Their well-established services center on turning excess assets into immediate cash through strategic store closings and wholesale, industrial, and healthcare liquidations
Services include auctions, reverse logistics and processing, store closure sales management, turnaround consulting, and retail liquidations
of consumer merchandise through 98 outlets across North America.
The alternatives to taking immediate action to mitigate the potential losses, including long-term funding strategies, hedging strategies and partial liquidations
, were felt to be inadequate in the circumstances.
The remaining assets from both liquidations
will be auctioned worldwide through DoveBid's proprietary state-of-art Webcast technology in which bidders at the auction site and around the globe can compete for assets through the Internet.