Internal Revenue Service
Revenue Ruling

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 Rev. Rul. 64-98

1964-1 C.B. 450

Sec. 6043

IRS Headnote

A dividend disbursing agent is not required to furnish a statement showing the information contained in Form 1099L, U.S. Information Return-Distributions in Liquidation During Calendar Year --, or a copy of Form 1099L, to shareholders receiving liquidating dividends.

Full Text

Rev. Rul. 64-98

Advice has been requested whether a dividend disbursing agent is required by the Internal Revenue Code of 1954 or the Income Tax Regulations promulgated thereunder to furnish a statement showing the information contained in a Form 1099L, U.S. Information Return-Distributions in Liquidation During Calendar Year -, or a copy of the Form 1099L, to each shareholder receiving a liquidating dividend.

Section 6043 of the Code provides, in effect, that every corporation shall, when required by the Secretary or his delegate, make a return regarding its distributions in liquidation showing the amount paid to each shareholder or, if the distribution is in property other than money, the fair market value of the property distributed to each shareholder.

Section 1.6043-2(a) of the regulations provides, in pertinent part, and with certain exceptions relating to liquidations of subsidiaries, corporate reorganizations, and exchanges ordered by the Securities and Exchange Commission, that every corporation making any distribution of $600 or more during a calendar year to any shareholder in liquidation of the whole or any part of its capital stock shall file a return on Forms 1096, U.S. Annual Information Return, and 1099L giving all the information required by the forms and by the regulations. A separate Form 1099L must be prepared with respect to each shareholder to whom such distribution was made and a single copy must be filed with the Internal Revenue Service.

It is held that a dividend disbursing agent is not required to furnish a statement of information or a copy of Form 1099L to shareholders receiving liquidating dividends. There would be no objection, however, to a private printing of these forms providing a copy for the payee if the payer so desires.