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    More likely however, the QSUB used its corporate trust parent's taxpayer identification number in filing its Form 355S, in which case a second note should be added to the QSUB's final return stating that "the taxpayer identification number appearing on this return will continue to be used by the S corporation formed as the result of the F reorganization described in Directive 1 of Directive 04-1, when filing its Form 355S with the Commonwealth." C. The Massachusetts corporate trust is not required to file a final return in the taxable year in which the reorganization takes place. In computing the aggregated total receipts, each entity required to aggregate total receipts must first compute its total receipts separately for the taxable year in which the reorganization takes place. Also, an actual accounting of the QSUB's net income for the period must be made. Computing QSUB's Non-Income Measure of Corporate Excise. A short taxable year is the only case in which the General Laws specifically allows for proration of the non-income measure of the corporate excise based on the number of months in the short year. 63 based solely on its own property, payroll, and sales. §§ 332 and 337 allowing for a tax-free liquidation of a subsidiary been allowed, those two sections do not represent the authority for this Directive. § 1.1361-4, the original QSUB election in the earlier LR 99-17 transaction resulted in the deemed liquidation of the QSUB into the S corporation for federal income tax purposes whether the liquidation was governed by IRC §§ 332, 337 or 368. The only factual difference between the two is that in LR 01-9, the stand-alone Massachusetts S corporation turned QSUB is a "financial institution" within the meaning of G. Thus, Directives 1, 2, and 4, will apply to the earlier case. 62, § 8 as a corporate trust, not as a financial institution under G. Pursuant to Example 8, the IRS characterizes the merger of an S corporation parent into its QSUB as a tax free "F" reorganization.

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