Liquidating Trust. A trust (i) meeting the requirements set forth in Internal Revenue Service Revenue Procedure 82-58, 1982-2 C.B. 848; (ii) that is at no time described in Section 851(a)(1) or Section 851(a)(2) of the Code; and (iii) that does not elect to be treated as a corporation for federal or applicable state tax purposes.
Appears in 3 contracts
Sources: Agreement and Plan of Reorganization (Wells Fargo Variable Trust), Agreement and Plan of Reorganization (Wells Fargo Funds Trust), Agreement and Plan of Reorganization (Wells Fargo Funds Trust)