Proportionate liquidating distribution

In addition, there is a helpful limitation on the gain a partner must recognize upon receiving a distribution of a marketable security.

The partner’s gain is reduced to the extent the distribution results in a decrease in the partner’s share of the net gain inherent in all of the partnership’s marketable securities.

The Fund expects to make two liquidating distributions to stockholders as of the Effective Date.

The first liquidating distribution will represent approximately 98% of the Fund’s net assets and is expected to be made on or about July 11, 2017.

Fundamentally, the tax law requires that any gain realized by the partnership on the disposition of the contributed property, for example, if the partnership sells the contributed property, must be allocated to the contributing partner to the extent of the property’s built-in gain. A’s built-in gain with respect to property P is 0 (0 value at contribution less A’s 0 basis).

It should not be expected to cover, at least not completely, the disproportionate distributions of marketable securities that may occur when a pick and choose approach is taken to distributing LLC assets to the owners in liquidation.

The Fund was organized as a corporation under the laws of Maryland on August 17, 1988 and has registered with the SEC under the Investment Company Act of 1940, as amended.

The Fund's principal office is located at 270 Park Avenue, New York, New York 10017. Morgan Investment Management Inc., an investment management firm registered with the SEC under the Investment Advisers Act of 1940.

ABC distributes the

It should not be expected to cover, at least not completely, the disproportionate distributions of marketable securities that may occur when a pick and choose approach is taken to distributing LLC assets to the owners in liquidation.

The Fund was organized as a corporation under the laws of Maryland on August 17, 1988 and has registered with the SEC under the Investment Company Act of 1940, as amended.

The Fund's principal office is located at 270 Park Avenue, New York, New York 10017. Morgan Investment Management Inc., an investment management firm registered with the SEC under the Investment Advisers Act of 1940.

ABC distributes the $1,000 of marketable securities to C in complete liquidation of her partnership interest. (Here, “actively traded” means that an established financial market exists for such property.) Interests in common trust funds or regulated investment companies (that is, mutual funds) are marketable securities.

Financial instruments convertible into money or marketable securities are also marketable securities, as are financial instruments the values of which are determined by reference to marketable securities.

||

It should not be expected to cover, at least not completely, the disproportionate distributions of marketable securities that may occur when a pick and choose approach is taken to distributing LLC assets to the owners in liquidation.The Fund was organized as a corporation under the laws of Maryland on August 17, 1988 and has registered with the SEC under the Investment Company Act of 1940, as amended.The Fund's principal office is located at 270 Park Avenue, New York, New York 10017. Morgan Investment Management Inc., an investment management firm registered with the SEC under the Investment Advisers Act of 1940.ABC distributes the $1,000 of marketable securities to C in complete liquidation of her partnership interest. (Here, “actively traded” means that an established financial market exists for such property.) Interests in common trust funds or regulated investment companies (that is, mutual funds) are marketable securities.Financial instruments convertible into money or marketable securities are also marketable securities, as are financial instruments the values of which are determined by reference to marketable securities.

,000 of marketable securities to C in complete liquidation of her partnership interest. (Here, “actively traded” means that an established financial market exists for such property.) Interests in common trust funds or regulated investment companies (that is, mutual funds) are marketable securities.

Financial instruments convertible into money or marketable securities are also marketable securities, as are financial instruments the values of which are determined by reference to marketable securities.

Leave a Reply