Business & farm

Form 966 is good to file.  This also puts the S corp on notice that you liquidated the company.

You need to meet with a tax professional as you can't just transfer assets from one entity to another for federal tax purposes; without potential tax consequences.

You had a taxable liquidation (you told the IRS you were liquidating on form 966) and a capital contribution.

This isn't a tax-free reorganization under Section 368 as there was no $$ paid by the acquiring entity for an acquisitive D reorganization.

In a divisive D reorganization, what you generally have is a corporation splitting into more than one entity; in the form of a of a split-up, a split-off, or a spinoff.

I don't believe you have a D reorganization; especially since you filed form 966 telling the IRS you liquidated.

This may qualify as an F reorganization, but you need to meet with a tax professional where you can have a one on one.  

 

 

*A reminder that posts in a forum such as this do not constitute tax advice.
Also keep in mind the date of replies, as tax law changes.