US Chief Counsel memo clarifies process for determining assessment statute expiration date in multi-year Section 332 liquidation

The assessment statute expiration date (ASED) for a multi-year Internal Revenue Code Section 332 liquidation is based on the first year of a liquidating distribution.

A parent must file Form 952, Consent to Extend the Time To Assess Tax Under Section 332(b), to waive the statute of limitations on assessment for each of its tax years that falls wholly or partly within the liquidation period.

The Chief Counsel clarifies that the Internal Revenue Service (IRS) should determine the ASED by thoroughly …