Fillable Form Form 952

What is Form 952?

Form 952, Consent to Extend the Time to Assess Tax Under Section 332(b), is an Internal Revenue Service (IRS) form used by a corporation to extend the deadline for assessing taxes on all proceeds of the liquidation of a subsidiary.

IRS Form 952 is used to extend the period of assessment of all income taxes of the receiving corporation on the complete liquidation of a subsidiary under section 332. The 952 form must be used if the liquidation will be completed within the three-year period following the end of the subsidiary’s tax year that the first distribution was made.

Liquidation is the process of selling all of an entity’s assets, paying off its debts, distributing any residual funds to shareholders, and closing the company down as a legal entity. The liquidation process is a possible outcome of bankruptcy, which occurs when a company’s assets are insufficient to satisfy its creditors.

As a general rule, gain or loss on the complete liquidation of a subsidiary is not recognized when the assets of the subsidiary are distributed. However, gain or loss will be recognized if the distribution is not complete within the three-year period or if the receiving corporation can no longer meet the requirements of section 1504(a)(2).

Under section 332(b), a distribution shall be considered to be a complete liquidation only if:

• The corporation receiving such property was, on the date of the adoption of the plan of liquidation, and has continued to be at all times until the receipt of the property, the owner of stock (in such other corporation) meeting the requirements of section 1504(a)(2);
• The distribution is by such other corporation in complete cancellation or redemption of all its stock, and the transfer of all the property occurs within the taxable year; in such case the adoption by the shareholders of the resolution under which is authorized the distribution of all the assets of such corporation in complete cancellation or redemption of all its stock shall be considered adoption of a plan of liquidation, even though no time for the completion of the transfer of the property is specified in such resolution;
• Such distribution is one of a series of distributions by such other corporation in complete cancellation or redemption of all its stock in accordance with a plan of liquidation under which the transfer of all the property under the liquidation is to be completed within three years from the close of the taxable year during which is made the first of the series of distributions under the plan, except that if such transfer is not completed within such period, or if the taxpayer does not continue qualified under the first paragraph until the completion of such transfer, no distribution under the plan shall be considered a distribution in complete liquidation.

If such transfer of all the property does not occur within the taxable year, the Secretary may require of the taxpayer such bond, or waiver of the statute of limitations on assessment and collection, or both, as he may deem necessary to insure, if the transfer of the property is not completed within such three-year-period, or if the taxpayer does not continue qualified under the first paragraph until the completion of such transfer, the assessment and collection of all income taxes then imposed by law for such taxable year or subsequent taxable years, to the extent attributable to property so received.

If all of the assets of the liquidating subsidiary will not be distributed to the receiving corporation by the end of the subsidiary’s tax year in which the first distribution was made under the plan of liquidation, then you must file IRS 952 form for each tax year or part of a tax year that falls within the period of liquidation. File IRS tax form 952 with the Ogden Submission Processing Center, P.O. Box 9941, Ogden, UT 84409-0941.

Form 952 establishes an extended period of assessing tax. The expiration of the extended period may be suspended or otherwise affected by the operation of law in the same manner as the original period. Under no circumstances will this form reduce the period of time otherwise provided by law for making an assessment.

How to fill out Form 952?

Filling out the 952 tax form is quick and simple. You can download and print a PDF copy of Form 952 from the Internal Revenue Service (IRS) website that you can manually complete. But for your convenience, you can also fill out Form 952 electronically on PDFRun. By following the instructions below, you can accomplish the form in minutes.

Name of receiving corporation

Enter the name of the receiving corporation.

Employer identification number

Enter the receiving corporation’s employer identification number.

Number, street, and room or suite no.

Enter the address where the receiving corporation is located, including the suite, room, or another unit number after the street address.

If the Post Office does not deliver mail to the street address and the corporation has a P.O. box, enter the box number instead.

City or town, state, and ZIP code

Enter the city or town, state, and ZIP code where the receiving corporation is located.

Name of subsidiary

Enter the name of the subsidiary.

Employer identification number

Enter the subsidiary’s employer identification number.

Address of subsidiary

Enter the address where the subsidiary is located, including the suite, room, or another unit number after the street address, city or town, state, and ZIP code.

If the same as the receiving corporation, leave this space blank.

Tax Year

Enter the ending of the tax year following the format: Month, Year.

Signature of Receiving Corporation’s Officer

Affix the receiving corporation’s officer’s signature.

Date signed

Enter the date the receiving corporation’s officer signed the form. Then, enter the title describing his or her role in the business.

If signed by an attorney or an agent of the receiving corporation, attach a copy of the authorization.

By

Affix the subsidiary representative’s signature.

Date signed

Enter the date the subsidiary representative signed the form.