At home liquidating trust

Although disregarded entity status is not typical for a trust, the reporting status of such a trust is essentially that of a grantor trust where trust income is taxed directly to the sole beneficiary as if received directly by the beneficiary (see Treas. For example, the trust liability shield should apply to beneficiaries who do not improperly participate in the management of trust affairs and the trust would continue to be a separate legal entity for contract law purposes. The trust instrument specifically provided that the trustee was to have no management power over the affairs of the trust but was merely to hold title to the real estate transferred to it, and to collect and distribute proceeds from the sale of the lots. This in turn requires some concerted, purposeful and voluntary effort on the part of the beneficiaries to either "plan or join" a pre- existing business activity for the "purpose of sharing the fruits" of its business activities. 334 (1984)), some further act on their part is necessary to satisfy the "associates" requirement.Partnership tax rules are different from normative taxation and some of the differences may create concerns. When the beneficiaries do not create the trust but receive their interests by gift (rather than by purchase, see Howard v. To apply this analysis, the Tax Court examined the trust instrument searching for a power of beneficiaries to share or influence the trustee's duties under the trust. 1207 (1986) and Field Service Advisory, 1993 Westlaw 1470195).

Business trusts were considered a corporation or a partnership depending on whether the trust's legal characteristics more closely resembled those of a corporation or a partnership. 344 (1935), the Kintner regulations provided that trusts possessing three of four identified corporate criteria were taxable as corporations (free transferability of interests, limited liability, centralized management, and continuity of life).

Whether a trust is considered an ordinary trust or a business trust depends on (1) whether the terms of the written trust instrument grants the trustee broad powers to engage in a business with the trust property and (2) whether the trust also has associates. The tax regulations define a liquidating trust as one created for the primary purpose of "liquidating and distributing its assets" (Treas. So viewed, a liquidating trust is not a business trust because it possesses only a liquidation objective (protect and conserve) rather than a broader business objective. While several pre-check-the-box private letter tax rulings considered the status of liquidating trusts, no noticeable post-1997 rulings have been released.

This is true regardless of whether the business purpose powers are necessary for a particular trust and regardless of whether the trustee actually exercises those powers. However, if the existence of the trust is unreasonably prolonged or if the liquidation purpose becomes sufficiently obscured or abandoned by business activities, the trust will "become" a business trust. No doubt this is attributable to the fact that after that date, a failed liquidating trust will merely be treated as an unincorporated business entity and thus as a partnership (two or more beneficiaries) or disregarded entity (grantor trust status if single beneficiary).

12, 2018 (GLOBE NEWSWIRE) -- Winthrop Realty Liquidating Trust (the "Trust") announced today that the Trust's trustees have approved a liquidating distribution of

Business trusts were considered a corporation or a partnership depending on whether the trust's legal characteristics more closely resembled those of a corporation or a partnership. 344 (1935), the Kintner regulations provided that trusts possessing three of four identified corporate criteria were taxable as corporations (free transferability of interests, limited liability, centralized management, and continuity of life).Whether a trust is considered an ordinary trust or a business trust depends on (1) whether the terms of the written trust instrument grants the trustee broad powers to engage in a business with the trust property and (2) whether the trust also has associates. The tax regulations define a liquidating trust as one created for the primary purpose of "liquidating and distributing its assets" (Treas. So viewed, a liquidating trust is not a business trust because it possesses only a liquidation objective (protect and conserve) rather than a broader business objective. While several pre-check-the-box private letter tax rulings considered the status of liquidating trusts, no noticeable post-1997 rulings have been released.This is true regardless of whether the business purpose powers are necessary for a particular trust and regardless of whether the trustee actually exercises those powers. However, if the existence of the trust is unreasonably prolonged or if the liquidation purpose becomes sufficiently obscured or abandoned by business activities, the trust will "become" a business trust. No doubt this is attributable to the fact that after that date, a failed liquidating trust will merely be treated as an unincorporated business entity and thus as a partnership (two or more beneficiaries) or disregarded entity (grantor trust status if single beneficiary). 12, 2018 (GLOBE NEWSWIRE) -- Winthrop Realty Liquidating Trust (the "Trust") announced today that the Trust's trustees have approved a liquidating distribution of

Business trusts were considered a corporation or a partnership depending on whether the trust's legal characteristics more closely resembled those of a corporation or a partnership. 344 (1935), the Kintner regulations provided that trusts possessing three of four identified corporate criteria were taxable as corporations (free transferability of interests, limited liability, centralized management, and continuity of life).Whether a trust is considered an ordinary trust or a business trust depends on (1) whether the terms of the written trust instrument grants the trustee broad powers to engage in a business with the trust property and (2) whether the trust also has associates. The tax regulations define a liquidating trust as one created for the primary purpose of "liquidating and distributing its assets" (Treas. So viewed, a liquidating trust is not a business trust because it possesses only a liquidation objective (protect and conserve) rather than a broader business objective. While several pre-check-the-box private letter tax rulings considered the status of liquidating trusts, no noticeable post-1997 rulings have been released.This is true regardless of whether the business purpose powers are necessary for a particular trust and regardless of whether the trustee actually exercises those powers. However, if the existence of the trust is unreasonably prolonged or if the liquidation purpose becomes sufficiently obscured or abandoned by business activities, the trust will "become" a business trust. No doubt this is attributable to the fact that after that date, a failed liquidating trust will merely be treated as an unincorporated business entity and thus as a partnership (two or more beneficiaries) or disregarded entity (grantor trust status if single beneficiary). 12, 2018 (GLOBE NEWSWIRE) -- Winthrop Realty Liquidating Trust (the "Trust") announced today that the Trust's trustees have approved a liquidating distribution of [[

Business trusts were considered a corporation or a partnership depending on whether the trust's legal characteristics more closely resembled those of a corporation or a partnership. 344 (1935), the Kintner regulations provided that trusts possessing three of four identified corporate criteria were taxable as corporations (free transferability of interests, limited liability, centralized management, and continuity of life).

Whether a trust is considered an ordinary trust or a business trust depends on (1) whether the terms of the written trust instrument grants the trustee broad powers to engage in a business with the trust property and (2) whether the trust also has associates. The tax regulations define a liquidating trust as one created for the primary purpose of "liquidating and distributing its assets" (Treas. So viewed, a liquidating trust is not a business trust because it possesses only a liquidation objective (protect and conserve) rather than a broader business objective. While several pre-check-the-box private letter tax rulings considered the status of liquidating trusts, no noticeable post-1997 rulings have been released.

This is true regardless of whether the business purpose powers are necessary for a particular trust and regardless of whether the trustee actually exercises those powers. However, if the existence of the trust is unreasonably prolonged or if the liquidation purpose becomes sufficiently obscured or abandoned by business activities, the trust will "become" a business trust. No doubt this is attributable to the fact that after that date, a failed liquidating trust will merely be treated as an unincorporated business entity and thus as a partnership (two or more beneficiaries) or disregarded entity (grantor trust status if single beneficiary).

12, 2018 (GLOBE NEWSWIRE) -- Winthrop Realty Liquidating Trust (the "Trust") announced today that the Trust's trustees have approved a liquidating distribution of $0.40 per common beneficial unit in the Trust payable in cash on October 22, 2018 to holders of record on October 15, BOSTON, June 19, 2018 (GLOBE NEWSWIRE) -- Winthrop Realty Liquidating Trust (the "Trust") announced today that the Trust's trustees have approved a liquidating distribution of $0.50 per common beneficial unit in the Trust payable in cash on June 27, 2018 to holders of record on June 20, 2018.

The BOSTON, April 30, 2018 (GLOBE NEWSWIRE) -- Winthrop Realty Liquidating Trust (the "Trust") announced today the sale of 701 Seventh Avenue property (a/k/a 20 Times Square) in the Times Square area of Manhattan, New York for a gross sales price of $1.53 billion.

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Business trusts were considered a corporation or a partnership depending on whether the trust's legal characteristics more closely resembled those of a corporation or a partnership. 344 (1935), the Kintner regulations provided that trusts possessing three of four identified corporate criteria were taxable as corporations (free transferability of interests, limited liability, centralized management, and continuity of life).Whether a trust is considered an ordinary trust or a business trust depends on (1) whether the terms of the written trust instrument grants the trustee broad powers to engage in a business with the trust property and (2) whether the trust also has associates. The tax regulations define a liquidating trust as one created for the primary purpose of "liquidating and distributing its assets" (Treas. So viewed, a liquidating trust is not a business trust because it possesses only a liquidation objective (protect and conserve) rather than a broader business objective. While several pre-check-the-box private letter tax rulings considered the status of liquidating trusts, no noticeable post-1997 rulings have been released.This is true regardless of whether the business purpose powers are necessary for a particular trust and regardless of whether the trustee actually exercises those powers. However, if the existence of the trust is unreasonably prolonged or if the liquidation purpose becomes sufficiently obscured or abandoned by business activities, the trust will "become" a business trust. No doubt this is attributable to the fact that after that date, a failed liquidating trust will merely be treated as an unincorporated business entity and thus as a partnership (two or more beneficiaries) or disregarded entity (grantor trust status if single beneficiary). 12, 2018 (GLOBE NEWSWIRE) -- Winthrop Realty Liquidating Trust (the "Trust") announced today that the Trust's trustees have approved a liquidating distribution of $0.40 per common beneficial unit in the Trust payable in cash on October 22, 2018 to holders of record on October 15, BOSTON, June 19, 2018 (GLOBE NEWSWIRE) -- Winthrop Realty Liquidating Trust (the "Trust") announced today that the Trust's trustees have approved a liquidating distribution of $0.50 per common beneficial unit in the Trust payable in cash on June 27, 2018 to holders of record on June 20, 2018.The BOSTON, April 30, 2018 (GLOBE NEWSWIRE) -- Winthrop Realty Liquidating Trust (the "Trust") announced today the sale of 701 Seventh Avenue property (a/k/a 20 Times Square) in the Times Square area of Manhattan, New York for a gross sales price of $1.53 billion.

]].40 per common beneficial unit in the Trust payable in cash on October 22, 2018 to holders of record on October 15, BOSTON, June 19, 2018 (GLOBE NEWSWIRE) -- Winthrop Realty Liquidating Trust (the "Trust") announced today that the Trust's trustees have approved a liquidating distribution of [[

Business trusts were considered a corporation or a partnership depending on whether the trust's legal characteristics more closely resembled those of a corporation or a partnership. 344 (1935), the Kintner regulations provided that trusts possessing three of four identified corporate criteria were taxable as corporations (free transferability of interests, limited liability, centralized management, and continuity of life).

Whether a trust is considered an ordinary trust or a business trust depends on (1) whether the terms of the written trust instrument grants the trustee broad powers to engage in a business with the trust property and (2) whether the trust also has associates. The tax regulations define a liquidating trust as one created for the primary purpose of "liquidating and distributing its assets" (Treas. So viewed, a liquidating trust is not a business trust because it possesses only a liquidation objective (protect and conserve) rather than a broader business objective. While several pre-check-the-box private letter tax rulings considered the status of liquidating trusts, no noticeable post-1997 rulings have been released.

This is true regardless of whether the business purpose powers are necessary for a particular trust and regardless of whether the trustee actually exercises those powers. However, if the existence of the trust is unreasonably prolonged or if the liquidation purpose becomes sufficiently obscured or abandoned by business activities, the trust will "become" a business trust. No doubt this is attributable to the fact that after that date, a failed liquidating trust will merely be treated as an unincorporated business entity and thus as a partnership (two or more beneficiaries) or disregarded entity (grantor trust status if single beneficiary).

12, 2018 (GLOBE NEWSWIRE) -- Winthrop Realty Liquidating Trust (the "Trust") announced today that the Trust's trustees have approved a liquidating distribution of $0.40 per common beneficial unit in the Trust payable in cash on October 22, 2018 to holders of record on October 15, BOSTON, June 19, 2018 (GLOBE NEWSWIRE) -- Winthrop Realty Liquidating Trust (the "Trust") announced today that the Trust's trustees have approved a liquidating distribution of $0.50 per common beneficial unit in the Trust payable in cash on June 27, 2018 to holders of record on June 20, 2018.

The BOSTON, April 30, 2018 (GLOBE NEWSWIRE) -- Winthrop Realty Liquidating Trust (the "Trust") announced today the sale of 701 Seventh Avenue property (a/k/a 20 Times Square) in the Times Square area of Manhattan, New York for a gross sales price of $1.53 billion.

||

Business trusts were considered a corporation or a partnership depending on whether the trust's legal characteristics more closely resembled those of a corporation or a partnership. 344 (1935), the Kintner regulations provided that trusts possessing three of four identified corporate criteria were taxable as corporations (free transferability of interests, limited liability, centralized management, and continuity of life).Whether a trust is considered an ordinary trust or a business trust depends on (1) whether the terms of the written trust instrument grants the trustee broad powers to engage in a business with the trust property and (2) whether the trust also has associates. The tax regulations define a liquidating trust as one created for the primary purpose of "liquidating and distributing its assets" (Treas. So viewed, a liquidating trust is not a business trust because it possesses only a liquidation objective (protect and conserve) rather than a broader business objective. While several pre-check-the-box private letter tax rulings considered the status of liquidating trusts, no noticeable post-1997 rulings have been released.This is true regardless of whether the business purpose powers are necessary for a particular trust and regardless of whether the trustee actually exercises those powers. However, if the existence of the trust is unreasonably prolonged or if the liquidation purpose becomes sufficiently obscured or abandoned by business activities, the trust will "become" a business trust. No doubt this is attributable to the fact that after that date, a failed liquidating trust will merely be treated as an unincorporated business entity and thus as a partnership (two or more beneficiaries) or disregarded entity (grantor trust status if single beneficiary). 12, 2018 (GLOBE NEWSWIRE) -- Winthrop Realty Liquidating Trust (the "Trust") announced today that the Trust's trustees have approved a liquidating distribution of $0.40 per common beneficial unit in the Trust payable in cash on October 22, 2018 to holders of record on October 15, BOSTON, June 19, 2018 (GLOBE NEWSWIRE) -- Winthrop Realty Liquidating Trust (the "Trust") announced today that the Trust's trustees have approved a liquidating distribution of $0.50 per common beneficial unit in the Trust payable in cash on June 27, 2018 to holders of record on June 20, 2018.The BOSTON, April 30, 2018 (GLOBE NEWSWIRE) -- Winthrop Realty Liquidating Trust (the "Trust") announced today the sale of 701 Seventh Avenue property (a/k/a 20 Times Square) in the Times Square area of Manhattan, New York for a gross sales price of $1.53 billion.

]].50 per common beneficial unit in the Trust payable in cash on June 27, 2018 to holders of record on June 20, 2018.The BOSTON, April 30, 2018 (GLOBE NEWSWIRE) -- Winthrop Realty Liquidating Trust (the "Trust") announced today the sale of 701 Seventh Avenue property (a/k/a 20 Times Square) in the Times Square area of Manhattan, New York for a gross sales price of

Business trusts were considered a corporation or a partnership depending on whether the trust's legal characteristics more closely resembled those of a corporation or a partnership. 344 (1935), the Kintner regulations provided that trusts possessing three of four identified corporate criteria were taxable as corporations (free transferability of interests, limited liability, centralized management, and continuity of life).

Whether a trust is considered an ordinary trust or a business trust depends on (1) whether the terms of the written trust instrument grants the trustee broad powers to engage in a business with the trust property and (2) whether the trust also has associates. The tax regulations define a liquidating trust as one created for the primary purpose of "liquidating and distributing its assets" (Treas. So viewed, a liquidating trust is not a business trust because it possesses only a liquidation objective (protect and conserve) rather than a broader business objective. While several pre-check-the-box private letter tax rulings considered the status of liquidating trusts, no noticeable post-1997 rulings have been released.

This is true regardless of whether the business purpose powers are necessary for a particular trust and regardless of whether the trustee actually exercises those powers. However, if the existence of the trust is unreasonably prolonged or if the liquidation purpose becomes sufficiently obscured or abandoned by business activities, the trust will "become" a business trust. No doubt this is attributable to the fact that after that date, a failed liquidating trust will merely be treated as an unincorporated business entity and thus as a partnership (two or more beneficiaries) or disregarded entity (grantor trust status if single beneficiary).

12, 2018 (GLOBE NEWSWIRE) -- Winthrop Realty Liquidating Trust (the "Trust") announced today that the Trust's trustees have approved a liquidating distribution of $0.40 per common beneficial unit in the Trust payable in cash on October 22, 2018 to holders of record on October 15, BOSTON, June 19, 2018 (GLOBE NEWSWIRE) -- Winthrop Realty Liquidating Trust (the "Trust") announced today that the Trust's trustees have approved a liquidating distribution of $0.50 per common beneficial unit in the Trust payable in cash on June 27, 2018 to holders of record on June 20, 2018.

The BOSTON, April 30, 2018 (GLOBE NEWSWIRE) -- Winthrop Realty Liquidating Trust (the "Trust") announced today the sale of 701 Seventh Avenue property (a/k/a 20 Times Square) in the Times Square area of Manhattan, New York for a gross sales price of $1.53 billion.

||

Business trusts were considered a corporation or a partnership depending on whether the trust's legal characteristics more closely resembled those of a corporation or a partnership. 344 (1935), the Kintner regulations provided that trusts possessing three of four identified corporate criteria were taxable as corporations (free transferability of interests, limited liability, centralized management, and continuity of life).Whether a trust is considered an ordinary trust or a business trust depends on (1) whether the terms of the written trust instrument grants the trustee broad powers to engage in a business with the trust property and (2) whether the trust also has associates. The tax regulations define a liquidating trust as one created for the primary purpose of "liquidating and distributing its assets" (Treas. So viewed, a liquidating trust is not a business trust because it possesses only a liquidation objective (protect and conserve) rather than a broader business objective. While several pre-check-the-box private letter tax rulings considered the status of liquidating trusts, no noticeable post-1997 rulings have been released.This is true regardless of whether the business purpose powers are necessary for a particular trust and regardless of whether the trustee actually exercises those powers. However, if the existence of the trust is unreasonably prolonged or if the liquidation purpose becomes sufficiently obscured or abandoned by business activities, the trust will "become" a business trust. No doubt this is attributable to the fact that after that date, a failed liquidating trust will merely be treated as an unincorporated business entity and thus as a partnership (two or more beneficiaries) or disregarded entity (grantor trust status if single beneficiary). 12, 2018 (GLOBE NEWSWIRE) -- Winthrop Realty Liquidating Trust (the "Trust") announced today that the Trust's trustees have approved a liquidating distribution of $0.40 per common beneficial unit in the Trust payable in cash on October 22, 2018 to holders of record on October 15, BOSTON, June 19, 2018 (GLOBE NEWSWIRE) -- Winthrop Realty Liquidating Trust (the "Trust") announced today that the Trust's trustees have approved a liquidating distribution of $0.50 per common beneficial unit in the Trust payable in cash on June 27, 2018 to holders of record on June 20, 2018.The BOSTON, April 30, 2018 (GLOBE NEWSWIRE) -- Winthrop Realty Liquidating Trust (the "Trust") announced today the sale of 701 Seventh Avenue property (a/k/a 20 Times Square) in the Times Square area of Manhattan, New York for a gross sales price of $1.53 billion.

.53 billion.

.40 per common beneficial unit in the Trust payable in cash on October 22, 2018 to holders of record on October 15, BOSTON, June 19, 2018 (GLOBE NEWSWIRE) -- Winthrop Realty Liquidating Trust (the "Trust") announced today that the Trust's trustees have approved a liquidating distribution of [[

Business trusts were considered a corporation or a partnership depending on whether the trust's legal characteristics more closely resembled those of a corporation or a partnership. 344 (1935), the Kintner regulations provided that trusts possessing three of four identified corporate criteria were taxable as corporations (free transferability of interests, limited liability, centralized management, and continuity of life).

Whether a trust is considered an ordinary trust or a business trust depends on (1) whether the terms of the written trust instrument grants the trustee broad powers to engage in a business with the trust property and (2) whether the trust also has associates. The tax regulations define a liquidating trust as one created for the primary purpose of "liquidating and distributing its assets" (Treas. So viewed, a liquidating trust is not a business trust because it possesses only a liquidation objective (protect and conserve) rather than a broader business objective. While several pre-check-the-box private letter tax rulings considered the status of liquidating trusts, no noticeable post-1997 rulings have been released.

This is true regardless of whether the business purpose powers are necessary for a particular trust and regardless of whether the trustee actually exercises those powers. However, if the existence of the trust is unreasonably prolonged or if the liquidation purpose becomes sufficiently obscured or abandoned by business activities, the trust will "become" a business trust. No doubt this is attributable to the fact that after that date, a failed liquidating trust will merely be treated as an unincorporated business entity and thus as a partnership (two or more beneficiaries) or disregarded entity (grantor trust status if single beneficiary).

12, 2018 (GLOBE NEWSWIRE) -- Winthrop Realty Liquidating Trust (the "Trust") announced today that the Trust's trustees have approved a liquidating distribution of $0.40 per common beneficial unit in the Trust payable in cash on October 22, 2018 to holders of record on October 15, BOSTON, June 19, 2018 (GLOBE NEWSWIRE) -- Winthrop Realty Liquidating Trust (the "Trust") announced today that the Trust's trustees have approved a liquidating distribution of $0.50 per common beneficial unit in the Trust payable in cash on June 27, 2018 to holders of record on June 20, 2018.

The BOSTON, April 30, 2018 (GLOBE NEWSWIRE) -- Winthrop Realty Liquidating Trust (the "Trust") announced today the sale of 701 Seventh Avenue property (a/k/a 20 Times Square) in the Times Square area of Manhattan, New York for a gross sales price of $1.53 billion.

||

Business trusts were considered a corporation or a partnership depending on whether the trust's legal characteristics more closely resembled those of a corporation or a partnership. 344 (1935), the Kintner regulations provided that trusts possessing three of four identified corporate criteria were taxable as corporations (free transferability of interests, limited liability, centralized management, and continuity of life).Whether a trust is considered an ordinary trust or a business trust depends on (1) whether the terms of the written trust instrument grants the trustee broad powers to engage in a business with the trust property and (2) whether the trust also has associates. The tax regulations define a liquidating trust as one created for the primary purpose of "liquidating and distributing its assets" (Treas. So viewed, a liquidating trust is not a business trust because it possesses only a liquidation objective (protect and conserve) rather than a broader business objective. While several pre-check-the-box private letter tax rulings considered the status of liquidating trusts, no noticeable post-1997 rulings have been released.This is true regardless of whether the business purpose powers are necessary for a particular trust and regardless of whether the trustee actually exercises those powers. However, if the existence of the trust is unreasonably prolonged or if the liquidation purpose becomes sufficiently obscured or abandoned by business activities, the trust will "become" a business trust. No doubt this is attributable to the fact that after that date, a failed liquidating trust will merely be treated as an unincorporated business entity and thus as a partnership (two or more beneficiaries) or disregarded entity (grantor trust status if single beneficiary). 12, 2018 (GLOBE NEWSWIRE) -- Winthrop Realty Liquidating Trust (the "Trust") announced today that the Trust's trustees have approved a liquidating distribution of $0.40 per common beneficial unit in the Trust payable in cash on October 22, 2018 to holders of record on October 15, BOSTON, June 19, 2018 (GLOBE NEWSWIRE) -- Winthrop Realty Liquidating Trust (the "Trust") announced today that the Trust's trustees have approved a liquidating distribution of $0.50 per common beneficial unit in the Trust payable in cash on June 27, 2018 to holders of record on June 20, 2018.The BOSTON, April 30, 2018 (GLOBE NEWSWIRE) -- Winthrop Realty Liquidating Trust (the "Trust") announced today the sale of 701 Seventh Avenue property (a/k/a 20 Times Square) in the Times Square area of Manhattan, New York for a gross sales price of $1.53 billion.

]].50 per common beneficial unit in the Trust payable in cash on June 27, 2018 to holders of record on June 20, 2018.The BOSTON, April 30, 2018 (GLOBE NEWSWIRE) -- Winthrop Realty Liquidating Trust (the "Trust") announced today the sale of 701 Seventh Avenue property (a/k/a 20 Times Square) in the Times Square area of Manhattan, New York for a gross sales price of

Business trusts were considered a corporation or a partnership depending on whether the trust's legal characteristics more closely resembled those of a corporation or a partnership. 344 (1935), the Kintner regulations provided that trusts possessing three of four identified corporate criteria were taxable as corporations (free transferability of interests, limited liability, centralized management, and continuity of life).

Whether a trust is considered an ordinary trust or a business trust depends on (1) whether the terms of the written trust instrument grants the trustee broad powers to engage in a business with the trust property and (2) whether the trust also has associates. The tax regulations define a liquidating trust as one created for the primary purpose of "liquidating and distributing its assets" (Treas. So viewed, a liquidating trust is not a business trust because it possesses only a liquidation objective (protect and conserve) rather than a broader business objective. While several pre-check-the-box private letter tax rulings considered the status of liquidating trusts, no noticeable post-1997 rulings have been released.

This is true regardless of whether the business purpose powers are necessary for a particular trust and regardless of whether the trustee actually exercises those powers. However, if the existence of the trust is unreasonably prolonged or if the liquidation purpose becomes sufficiently obscured or abandoned by business activities, the trust will "become" a business trust. No doubt this is attributable to the fact that after that date, a failed liquidating trust will merely be treated as an unincorporated business entity and thus as a partnership (two or more beneficiaries) or disregarded entity (grantor trust status if single beneficiary).

12, 2018 (GLOBE NEWSWIRE) -- Winthrop Realty Liquidating Trust (the "Trust") announced today that the Trust's trustees have approved a liquidating distribution of $0.40 per common beneficial unit in the Trust payable in cash on October 22, 2018 to holders of record on October 15, BOSTON, June 19, 2018 (GLOBE NEWSWIRE) -- Winthrop Realty Liquidating Trust (the "Trust") announced today that the Trust's trustees have approved a liquidating distribution of $0.50 per common beneficial unit in the Trust payable in cash on June 27, 2018 to holders of record on June 20, 2018.

The BOSTON, April 30, 2018 (GLOBE NEWSWIRE) -- Winthrop Realty Liquidating Trust (the "Trust") announced today the sale of 701 Seventh Avenue property (a/k/a 20 Times Square) in the Times Square area of Manhattan, New York for a gross sales price of $1.53 billion.

||

Business trusts were considered a corporation or a partnership depending on whether the trust's legal characteristics more closely resembled those of a corporation or a partnership. 344 (1935), the Kintner regulations provided that trusts possessing three of four identified corporate criteria were taxable as corporations (free transferability of interests, limited liability, centralized management, and continuity of life).Whether a trust is considered an ordinary trust or a business trust depends on (1) whether the terms of the written trust instrument grants the trustee broad powers to engage in a business with the trust property and (2) whether the trust also has associates. The tax regulations define a liquidating trust as one created for the primary purpose of "liquidating and distributing its assets" (Treas. So viewed, a liquidating trust is not a business trust because it possesses only a liquidation objective (protect and conserve) rather than a broader business objective. While several pre-check-the-box private letter tax rulings considered the status of liquidating trusts, no noticeable post-1997 rulings have been released.This is true regardless of whether the business purpose powers are necessary for a particular trust and regardless of whether the trustee actually exercises those powers. However, if the existence of the trust is unreasonably prolonged or if the liquidation purpose becomes sufficiently obscured or abandoned by business activities, the trust will "become" a business trust. No doubt this is attributable to the fact that after that date, a failed liquidating trust will merely be treated as an unincorporated business entity and thus as a partnership (two or more beneficiaries) or disregarded entity (grantor trust status if single beneficiary). 12, 2018 (GLOBE NEWSWIRE) -- Winthrop Realty Liquidating Trust (the "Trust") announced today that the Trust's trustees have approved a liquidating distribution of $0.40 per common beneficial unit in the Trust payable in cash on October 22, 2018 to holders of record on October 15, BOSTON, June 19, 2018 (GLOBE NEWSWIRE) -- Winthrop Realty Liquidating Trust (the "Trust") announced today that the Trust's trustees have approved a liquidating distribution of $0.50 per common beneficial unit in the Trust payable in cash on June 27, 2018 to holders of record on June 20, 2018.The BOSTON, April 30, 2018 (GLOBE NEWSWIRE) -- Winthrop Realty Liquidating Trust (the "Trust") announced today the sale of 701 Seventh Avenue property (a/k/a 20 Times Square) in the Times Square area of Manhattan, New York for a gross sales price of $1.53 billion.

.53 billion.

.40 per common beneficial unit in the Trust payable in cash on October 22, 2018 to holders of record on October 15, BOSTON, June 19, 2018 (GLOBE NEWSWIRE) -- Winthrop Realty Liquidating Trust (the "Trust") announced today that the Trust's trustees have approved a liquidating distribution of [[

Business trusts were considered a corporation or a partnership depending on whether the trust's legal characteristics more closely resembled those of a corporation or a partnership. 344 (1935), the Kintner regulations provided that trusts possessing three of four identified corporate criteria were taxable as corporations (free transferability of interests, limited liability, centralized management, and continuity of life).

Whether a trust is considered an ordinary trust or a business trust depends on (1) whether the terms of the written trust instrument grants the trustee broad powers to engage in a business with the trust property and (2) whether the trust also has associates. The tax regulations define a liquidating trust as one created for the primary purpose of "liquidating and distributing its assets" (Treas. So viewed, a liquidating trust is not a business trust because it possesses only a liquidation objective (protect and conserve) rather than a broader business objective. While several pre-check-the-box private letter tax rulings considered the status of liquidating trusts, no noticeable post-1997 rulings have been released.

This is true regardless of whether the business purpose powers are necessary for a particular trust and regardless of whether the trustee actually exercises those powers. However, if the existence of the trust is unreasonably prolonged or if the liquidation purpose becomes sufficiently obscured or abandoned by business activities, the trust will "become" a business trust. No doubt this is attributable to the fact that after that date, a failed liquidating trust will merely be treated as an unincorporated business entity and thus as a partnership (two or more beneficiaries) or disregarded entity (grantor trust status if single beneficiary).

12, 2018 (GLOBE NEWSWIRE) -- Winthrop Realty Liquidating Trust (the "Trust") announced today that the Trust's trustees have approved a liquidating distribution of $0.40 per common beneficial unit in the Trust payable in cash on October 22, 2018 to holders of record on October 15, BOSTON, June 19, 2018 (GLOBE NEWSWIRE) -- Winthrop Realty Liquidating Trust (the "Trust") announced today that the Trust's trustees have approved a liquidating distribution of $0.50 per common beneficial unit in the Trust payable in cash on June 27, 2018 to holders of record on June 20, 2018.

The BOSTON, April 30, 2018 (GLOBE NEWSWIRE) -- Winthrop Realty Liquidating Trust (the "Trust") announced today the sale of 701 Seventh Avenue property (a/k/a 20 Times Square) in the Times Square area of Manhattan, New York for a gross sales price of $1.53 billion.

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Business trusts were considered a corporation or a partnership depending on whether the trust's legal characteristics more closely resembled those of a corporation or a partnership. 344 (1935), the Kintner regulations provided that trusts possessing three of four identified corporate criteria were taxable as corporations (free transferability of interests, limited liability, centralized management, and continuity of life).Whether a trust is considered an ordinary trust or a business trust depends on (1) whether the terms of the written trust instrument grants the trustee broad powers to engage in a business with the trust property and (2) whether the trust also has associates. The tax regulations define a liquidating trust as one created for the primary purpose of "liquidating and distributing its assets" (Treas. So viewed, a liquidating trust is not a business trust because it possesses only a liquidation objective (protect and conserve) rather than a broader business objective. While several pre-check-the-box private letter tax rulings considered the status of liquidating trusts, no noticeable post-1997 rulings have been released.This is true regardless of whether the business purpose powers are necessary for a particular trust and regardless of whether the trustee actually exercises those powers. However, if the existence of the trust is unreasonably prolonged or if the liquidation purpose becomes sufficiently obscured or abandoned by business activities, the trust will "become" a business trust. No doubt this is attributable to the fact that after that date, a failed liquidating trust will merely be treated as an unincorporated business entity and thus as a partnership (two or more beneficiaries) or disregarded entity (grantor trust status if single beneficiary). 12, 2018 (GLOBE NEWSWIRE) -- Winthrop Realty Liquidating Trust (the "Trust") announced today that the Trust's trustees have approved a liquidating distribution of $0.40 per common beneficial unit in the Trust payable in cash on October 22, 2018 to holders of record on October 15, BOSTON, June 19, 2018 (GLOBE NEWSWIRE) -- Winthrop Realty Liquidating Trust (the "Trust") announced today that the Trust's trustees have approved a liquidating distribution of $0.50 per common beneficial unit in the Trust payable in cash on June 27, 2018 to holders of record on June 20, 2018.The BOSTON, April 30, 2018 (GLOBE NEWSWIRE) -- Winthrop Realty Liquidating Trust (the "Trust") announced today the sale of 701 Seventh Avenue property (a/k/a 20 Times Square) in the Times Square area of Manhattan, New York for a gross sales price of $1.53 billion.

]].50 per common beneficial unit in the Trust payable in cash on June 27, 2018 to holders of record on June 20, 2018.

The BOSTON, April 30, 2018 (GLOBE NEWSWIRE) -- Winthrop Realty Liquidating Trust (the "Trust") announced today the sale of 701 Seventh Avenue property (a/k/a 20 Times Square) in the Times Square area of Manhattan, New York for a gross sales price of

Business trusts were considered a corporation or a partnership depending on whether the trust's legal characteristics more closely resembled those of a corporation or a partnership. 344 (1935), the Kintner regulations provided that trusts possessing three of four identified corporate criteria were taxable as corporations (free transferability of interests, limited liability, centralized management, and continuity of life).

Whether a trust is considered an ordinary trust or a business trust depends on (1) whether the terms of the written trust instrument grants the trustee broad powers to engage in a business with the trust property and (2) whether the trust also has associates. The tax regulations define a liquidating trust as one created for the primary purpose of "liquidating and distributing its assets" (Treas. So viewed, a liquidating trust is not a business trust because it possesses only a liquidation objective (protect and conserve) rather than a broader business objective. While several pre-check-the-box private letter tax rulings considered the status of liquidating trusts, no noticeable post-1997 rulings have been released.

This is true regardless of whether the business purpose powers are necessary for a particular trust and regardless of whether the trustee actually exercises those powers. However, if the existence of the trust is unreasonably prolonged or if the liquidation purpose becomes sufficiently obscured or abandoned by business activities, the trust will "become" a business trust. No doubt this is attributable to the fact that after that date, a failed liquidating trust will merely be treated as an unincorporated business entity and thus as a partnership (two or more beneficiaries) or disregarded entity (grantor trust status if single beneficiary).

12, 2018 (GLOBE NEWSWIRE) -- Winthrop Realty Liquidating Trust (the "Trust") announced today that the Trust's trustees have approved a liquidating distribution of $0.40 per common beneficial unit in the Trust payable in cash on October 22, 2018 to holders of record on October 15, BOSTON, June 19, 2018 (GLOBE NEWSWIRE) -- Winthrop Realty Liquidating Trust (the "Trust") announced today that the Trust's trustees have approved a liquidating distribution of $0.50 per common beneficial unit in the Trust payable in cash on June 27, 2018 to holders of record on June 20, 2018.

The BOSTON, April 30, 2018 (GLOBE NEWSWIRE) -- Winthrop Realty Liquidating Trust (the "Trust") announced today the sale of 701 Seventh Avenue property (a/k/a 20 Times Square) in the Times Square area of Manhattan, New York for a gross sales price of $1.53 billion.

||

Business trusts were considered a corporation or a partnership depending on whether the trust's legal characteristics more closely resembled those of a corporation or a partnership. 344 (1935), the Kintner regulations provided that trusts possessing three of four identified corporate criteria were taxable as corporations (free transferability of interests, limited liability, centralized management, and continuity of life).Whether a trust is considered an ordinary trust or a business trust depends on (1) whether the terms of the written trust instrument grants the trustee broad powers to engage in a business with the trust property and (2) whether the trust also has associates. The tax regulations define a liquidating trust as one created for the primary purpose of "liquidating and distributing its assets" (Treas. So viewed, a liquidating trust is not a business trust because it possesses only a liquidation objective (protect and conserve) rather than a broader business objective. While several pre-check-the-box private letter tax rulings considered the status of liquidating trusts, no noticeable post-1997 rulings have been released.This is true regardless of whether the business purpose powers are necessary for a particular trust and regardless of whether the trustee actually exercises those powers. However, if the existence of the trust is unreasonably prolonged or if the liquidation purpose becomes sufficiently obscured or abandoned by business activities, the trust will "become" a business trust. No doubt this is attributable to the fact that after that date, a failed liquidating trust will merely be treated as an unincorporated business entity and thus as a partnership (two or more beneficiaries) or disregarded entity (grantor trust status if single beneficiary). 12, 2018 (GLOBE NEWSWIRE) -- Winthrop Realty Liquidating Trust (the "Trust") announced today that the Trust's trustees have approved a liquidating distribution of $0.40 per common beneficial unit in the Trust payable in cash on October 22, 2018 to holders of record on October 15, BOSTON, June 19, 2018 (GLOBE NEWSWIRE) -- Winthrop Realty Liquidating Trust (the "Trust") announced today that the Trust's trustees have approved a liquidating distribution of $0.50 per common beneficial unit in the Trust payable in cash on June 27, 2018 to holders of record on June 20, 2018.The BOSTON, April 30, 2018 (GLOBE NEWSWIRE) -- Winthrop Realty Liquidating Trust (the "Trust") announced today the sale of 701 Seventh Avenue property (a/k/a 20 Times Square) in the Times Square area of Manhattan, New York for a gross sales price of $1.53 billion.

.53 billion.

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