The Internal Revenue Service’s recently issued general legal advice memorandum (GLAM) should provide beneficial results to certain taxpayers that use a check-the-box election to convert an insolvent foreign corporation into a partnership.
Overview
The Internal Revenue Service (IRS) recently issued a generic legal advice memorandum, AM2011-003 (the GLAM), that is quite noteworthy. The GLAM addresses a common fact pattern where a check-the-box election is made to convert an insolvent foreign corporation into a partnership. As described below, the GLAM will be of primary significance for taxpayers under audit or in litigation.
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