(6) IRM 5.17.14.2.4: Revised title and updated section contents for accuracy, clarity, continuity, and discuss nominee theory. (5) IRM 5.17.14.2.3: Revised title and updated section contents for accuracy, clarity, continuity, and discuss successor liability theory. (4) IRM 5.17.14.2.2: Revised title and updated section contents for accuracy, clarity, continuity, and discuss fiduciary liability theory. (3) IRM 5.17.14.2.1: Revised title and updated section contents for accuracy, clarity, continuity, and discuss transferee theory. Revised the section for continuity and clarity including using tables to set out the theories and cross-reference links as well as the administrative and judicial remedies. (2) IRM 5.17.14.2: Moved Third-Party Liability Overview to this section renumbering this and subsequent subsections to make room for the internal control requirements section. Sections relocated include: transferee, fiduciary, and successor liabilities as well as nominee and alter ego theories.
SOUTH CAROLINA ILLEGAL FRAUDULENT CONVEYANCE TO HIDE ASSETS MANUAL
(1) IRM 5.17.14.1: Revised title and added content to comply with the Internal Management Documents System, Internal Revenue Manual (IRM) internal control requirements. This revision adds the new Internal Management Document (IMD) control section, reorganizes, and updates guidance on third party liabilities. (1) This transmits revised IRM 5.17.14, Legal Reference Guide for Revenue Officers, Fraudulent Transfers and Transferee and Other Third Party Liability. Fraudulent Transfers and Transferee and Other Third Party Liabilityĥ.17.14 Fraudulent Transfers and Transferee and Other Third Party Liability Manual Transmittal Legal Reference Guide for Revenue Officers Section 14.
5.17.14.7.1 Enforcement in Nominee, Alter Ego, and Lien Tracing Transferee Situations.5.17.14.7 Nominee, Alter Ego, and Transferee Elements.5.17.14.6 Successor Liability as Primary Liability.5.17.14.5.7 Considerations: Assess Under IRC 6901 or File Suit.5.17.14.5.6.2 Defenses for the Transferee in a Fraudulent Transfer Suit.5.17.14.5.6.1 Statute of Limitations for a Fraudulent Transfer Suit.5.17.14.5.6 Suit to Set Aside a Fraudulent Transfer.5.17.14.5.5 Defenses to Transferee or Fiduciary Liability.5.17.14.5.4 Establishing Transferee or Fiduciary Liability by Suit.5.17.14.5.2.1 Periods of Limitation and Extensions for Assessment Under IRC 6901.5.17.14.5.1 Assessing Transferee and Fiduciary Liability.5.17.14.5 Methods of Collecting from a Transferee or Fiduciary.5.17.14.3.4 Extent of Transferee Liability.5.17.14.3.3.5 Transferee Liability of a Shareholder or Distributee of a Corporation.5.17.14.3.3.4 Successor Liability of a Corporation as a Transferee.5.17.14.3.3.2.2 Types of Fraud in a Fraudulent Transfer.5.17.14.3.3.2.1 Fraudulent Transfers Under Federal and State Law.5.17.14.3.3.2 Transferee Liability Based on Fraudulent Transfers ("In Equity" ).5.17.14.3.3.1 Transferee Liability Directly Imposed on the Transferee ("At Law" ).5.17.14.3.3 Establishing Transferee Liability.5.17.14.3.2 Collection from the Transferee is Secondary.5.17.14.3 Transferee Accountability in General.5.17.14.2 Third Party Liability Overview.5.17.14.1.4 Program Management and Review.5.17.14 Fraudulent Transfers and Transferee and Other Third Party Liability.
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