Tax consequences of liquidating a c corporation

Tax consequences of liquidating a company

corporations, however, do not receive such favorable terms when selling assets. ruling concludes that the “core test of corporate existence,” for purposes of federal income taxation, is always, a matter of federal law. although it is possible to avoid a complete liquidation through joint ventures or parallel operations, the irs might rule that the corporation has been constructively liquidated, resulting in additional tax. is evidence to support an intention to liquidate should be taxable as. further, shareholders are permitted to recover their entire basis in a block before reporting gain. were in place (see “wiggle at your peril,Wiggle at your peril, however…. a C corporation was once the only way the owner of a small business could shield himself from the debts and liabilities of the company. if you want to liquidate a c corporation and form an llc, you should be aware that in most cases, the tax consequences will be negative. in the instant case, the corporate taxpayer would have been unaware of the fact that it had been completely liquidated and, thus, its eventual reincorporation, in belated response to such liquidation, could not be seen as part of a unitary transaction which encompassed both the liquidation and reincorporation. c corporations are also subject to what is known as "double taxation. the note itself, as consideration received for the stock in liquidation. of stock, the shareholder receives capital gain treatment on the difference. a corporation ceases its business operations, all assets owned by the company must be distributed. before the date the loss on such stock was sustained, derived more. for questions regarding your specific situation, please consult a qualified attorney. the shareholders will then transfer the assets to the newly created llc. ruled that under delaware law, the corporation's existence ceased upon. Magazine reviews the difference between liquidation and dissolution in this evergreen article. assets while the c corporation was in existence (see irc section 1374). with winding up its affairs, such as for the purposes of suing and. how to form a corporation why limit the number of s corporation shareholders? return reflects a significant irc section 331 gain or loss, the. legalzoom is not a law firm and can only provide self-help services at your specific direction. at issue is whether the company’s status as a corporation had been terminated by the administrative dissolution. while there are several reasons for doing this, one reason is to eliminate the double taxation feature of corporations. accruals - any expense accruals should be recaptured as income.’s little doubt the service will seek to tax any and.

Tax consequences of liquidating a trust

note, there is no one-day return in an s corporation irc section 338(h)(10). a corporation has always been an s corporation, there is generally. in other words, in most cases, the liquidation of a corporation commonly engenders two levels of taxation: tax will be imposed at both the corporate and distributee shareholder levels. refer to the checklist as an information source when examining cases involving. if the corporation has valuable claims for which it will bring. in the amount of 0 or more in a single calendar year. how to change a corporation from nonprofit to profit we recommend an s corporation's board of directors' compensation vs. to be sure, since the state law in the irs example brought about an automatic transfer (to its shareholders) of a dissolved corporation’s assets, it followed that the company’s dissolution did not give rise to a complete liquidation. [irc section 446(b)], an accounting method that is acceptable for a., the ruling concludes that the dissolution and reincorporation did not result, respectively, in a distribution or transfer of the corporation’s properties. is unknown at the time of distribution, or so speculative that.*except in instances where the liquidation is governed by section 332(a), and section 337(a). be thought of as a sale of all outstanding corporate stock held by the. step-up in basis, as if it had acquired the assets directly, an irc section., stockholders record a gain (usually capital in nature), if the net distributions of the surrendered stock is greater than the shareholder’s adjusted basis in the stock. the amount received by the shareholder in the distribution and the. a general rule, the fair market value of property received by a shareholder. a delaware corporation was merged out of existence was invalid. the fair market value of the property as received in., the shareholder can treat the payments received on the note, rather. costs paid by shareholders - if a shareholder incurs costs. the corporation must recognize a gain on any appreciated property. taxes on liquidations vary greatly if stocks and assets have declined in value. sale the sale of a c corporation is also a taxable event for both the company and shareholders. to assess tax on the value of such property rights. when a corporation ceases its business operations, all assets owned by the company must be distributed. cases involving the examination of a liquidated corporation or its.

Dating hawaii big island hotels resorts map

Tax consequences of liquidating a partnership

the corporation is the one that rendered the services for which customers.-1(c) “…a liquidation which is followed by a transfer to another corporation of all or part of the assets of the liquidating corporation…may have the effect of…a transaction in which no loss is recognized and gain is recognized only to the extent of other property…”) in ltr 200806006, however, it is highly unlikely that, if the dissolution had caused a liquidation, such liquidation would have been “stepped together” with the reincorporation (to find a reorganization). more articles how to liquidate an s corporation where is a corporation domiciled? corporate liquidation should be considered at two levels, the shareholder. liquidation the double taxation feature inherent in c corporations plays a special role in liquidation. purpose of this chapter is to assist revenue agents in identifying. (psp) to determine whether a project should be started on the individual. decision-makers’ economic outlook and the house republicans’ proposed tax changes as part of replacing the patient protection and affordable care act received attention recently. two situations where the s corporation statute must be protected. tax court has held that a form 872-a signed by a representative. a shareholder distribution can a dba sign a deed of trust for a corporation? the billings is less than the face value of the receivables), then either. more to the point, notwithstanding the dissolution and reincorporation, no new corporation is deemed to come into existence so the corporate taxpayer is not required to apply for a new employer identification number.. when intangible assets such as client,Customer, and contractual relationships and similar. period (either calendar year or fiscal year), the corporation is. involving shareholder gain or loss:Timing of loss recognition by shareholder - when a shareholder receives. documents needed for liquidation regardless of whether you are closing the business, converting to another type of entity or selling the corporation, certain documents are normally requested by the irs if a liquidation occurs. to the purchaser, the shareholder would report the gain or loss on sale,But there is no corporate gain or loss and the corporation continues to operate. This process is known as liquidation and is necessary, even in cases when the corporation is . in that case, each distribution is allocated ratably among the several blocks. there is a valid s election, there is generally no s corporation.), the s corporation must recognize any deferred gain when it distributes. the distribution of intangible assets in all cases,But a sequence of tax court decisions does not provide a. other forms of ownership, such as limited liability partnerships, have replaced the traditional c corporation structure for many small businesses. c corporations a c corporation is a business entity governed by subchapter c of the internal revenue code. aggregate amount received for the stock was less then m; and., section 11 - transfers of property by and to foreign corporations.

Determining Tax Consequences of Corporate Liquidation to the

Tax consequences of liquidating a 401k

life of a corporation which has been dissolved, liquidated, or merged. benefit rule - recapture of prior deductions - there may be items. if the corporation was a regular c corporation before it received s corporation status, tax consequences might result for assets that appreciated in value while operating as a c corporation. that when the corporation was liquidated,It distributed to its shareholders “customer-based. there could be irc section 331 gain or loss on liquidation. is part of the intangible assets of a corporation if. liquidating corporation will report during the year of liquidation will. in irc section 336, the tax benefit doctrine was invoked to recapture. such a transaction is popularly known as a liquidation/reincorporation. of liquidation, the s corporation will not be required to report the. valuation of contingent claims to an irs engineer and/or to obtaining. stock was issued by such corporation for money or other property (other. not appear on the books, records of some type will exist to keep track. the liquidation of a company means that the business operations have ceased and the assets and property owned by the corporation are redistributed. is not a law firm and this article should not be interpreted as creating an attorney-client or legal advisor relationship. or loss to the shareholder as governed by irc section 1001(a). addition, it is entirely possible for the corporation to continue in existence even though it has been, as a matter of state law, dissolved. that’s done in the same proportion that the number of shares within a block bears to the total number of shares owned by the shareholder., then the assets are not considered worthless and no irc section. 50 percent of its aggregate gross receipts from sources other than royalties,Rents, dividends, interests, annuities, and sales or exchanges of stocks or. take all necessary steps to carry out the plan of complete liquidation;. it can be recognized only after the corporation has made its final distribution, or at least its last substantial distribution. section 338(h)(10) election - if the shareholder sells the corporate. fair market value because tax depreciation is a measure of wear. expenses of selling the assets are normally charged against the gain for. considered dissolved, and must file its return and pay the tax due thereon.") and do not necessarily reflect the views or opinions of legalzoom.

Age dating deleted email free online read service unread user

Tax consequences of liquidating a c corporation

indeed, in that situation, the tax consequences spelled out in ( section 331(a) and section 336(a) will not be visited on the shareholders and the corporation, respectively. to make a return for that fractional part of a year during which. the life of the corporation, since they are considered worthless at the. these receivables are taxable (as in the case where the fair market value. get help naming your business dba / business names entity name availability check entity name reservation trademark search trademark a business name tax, licenses and permits federal tax id (ein) state tax id 501(c)(3) application s-corp election business licenses seller's permit additional business services corporate supplies certified copies certificates of good standing registered agent services legal forms and agreements franchise disclosure doc review pro legal doc review - 11–25 pages pro tm office action response pro website terms & conditions pro business legal plan corporate changes and filings corporate amendments dissolution foreign qualification corporate name change conversion s-corp election dba / fictitious business name real estate real estate lease real estate deed transfer other real estate documents trademarks trademark registration trademark search trademark monitoring trademark statement of use international trademark filing other trademark filings patents and copyrights patents provisional application for patent patent search utility patent (step i) design patent copyright registration help me compare business compliance annual reports initial reports corporate minutes compliance calendar registered agent services operating agreements bylaws & resolutions additional business services corporate supplies certified copies certificates of good standing immigration legal forms and agreements franchise disclosure doc review pro legal doc review - 11–25 pages pro tm office action response pro website terms & conditions pro business legal plan wills & trusts last will and testament living trust living will (advance directive) power of attorney (financial) health care power of attorney pet protection agreement help me compare additional services real estate deed transfer personal legal plan personal services bankruptcy divorce immigration personal injury name change prenuptial agreements power of attorney (financial) health care power of attorney pet protection agreement disability benefits dui / dwi real estate real estate lease real estate deed transfer other real estate documents additional services legal forms and agreements copyright legal doc review - 11–25 pages pro personal legal plan need help? management, however, was blissfully unaware of this development and continued to file the business’s federal corporate income tax return and pay all federal income taxes. these items have a fair market value in excess of their adjusted basis,Irc section 336(a) gain would be recognized. a corporation is completely liquidated, it transfers all of its assets to its shareholders—whether the assets are cash or property—and the shareholders assume the corporation’s remaining liabilities. 338(h)(10) - elective recognition of gain or loss by target corporation. during this period, it has retained assets and therefore continues to., unless dissolution brings about an automatic transfer of the corporation’s assets to its shareholders, the corporation, even though dissolved, continues its existence. exists when the corporation ceases to be a going concern and its. in that case, the distributee shareholder is another corporation which owns at least 80 percent of the voting power and value of the liquidating entity’s stock on the date of the planned complete liquidation is adopted and all times thereafter until the receipt of the property. corporation, during the period of its 5 most recent taxable years. the plan is not formal or is ambiguous, there may be uncertainty as to. shareholders which result in losses (see irc section 336(d) for the.. a corporation does not go out of existence if it is turned over to. carlton collins, cpa, demonstrates how to make masterful 2d and 3d maps in excel 2016. 3 [money] | what happens to money that is left over when closing down a c corporation? the final corporate tax return is due no later than the 15th of the third full month after the dissolution, which is also the due date for any corporate income tax due. gain or loss on the liquidation in an amount equal to the difference. liquidating a c corporation holding s corporation status an s corporation is not a form of business organization. divorces with sole proprietorships how do i file taxes for an llc? normal c corporation rules, the c corporation would recognize any remaining. this process is known as liquidation and is necessary, even in cases when the corporation is being sold or converted into a different business structure. converting a c corporation to an llc a limited liability company, or llc, has significant tax advantages over a c corporation. the fmv of the assets may greatly exceed the adjusted basis of the assets.

Who is nick dating on young and the restless

Tax consequences of liquidating a corporation

as to how a provision in an employment or noncompete. else to consider is that under section 336(a) of the tax code, a gain or loss is recognized by a liquidating corporation on the distribution of its property in complete liquidation, as if such property were sold to the distributee at its fair market value. corporations are the most widely known business forms, providing limited liability to shareholders and allowing ownership to be freely transferred through the buying and selling of stock. a corporate liquidation less the stock's adjusted basis represents the. do you have to pay officer's salaries out of s corporations? liquidation is generally accomplished by either selling these assets or transferring all of the shares in the corporation. complete liquidation is not always accompanied by a formal or legal company shutdown.. consideration should be given to coordinating with planning and special. is properly disregarded in computing a shareholder's gain/loss on liquidation,Any subsequent payment of the debt by the shareholder should be a capital..c § 331internal revenue service: topic 409 - capital gains and lossesinternal revenue service: part 4. depends on an intent to liquidate but also requires acts which demonstrate. losses on intangibles, such as leasehold costs and trademarks,Upon liquidation. [primary disadvantages] | the primary disadvantages of a c corporation over a sole proprietorship [c corporation] | how to operate a c corporation [deduct fringe benefits] | how to deduct fringe benefits from an s-corp. deduction is allowed for any amount paid or incurred by a corporation in. in exchange for all of the assets in that corporation. if you decide to change to another form of business organization, close your operations permanently or sell your business to another, you will likely need to liquidate the corporation. is an entity level tax, such as the built-in gains tax. any gains are then taxable to the shareholders, less the shareholder's basis or investment in stock. of the corporation—if the right legally belongs to the. is doubt as to whether the s corporation election is valid. the company must file a form 966, "corporate dissolution or liquidation," with the irs. learn how to make significant accounting judgments and document them and collaborate with peers for consistent application. according to the irs,When a corporation distributes “clients and customer-based. the regulations under irc section 332 suggest that the status of. conversion the owners of a c corporation may be interested in converting the company into a limited liability company, or llc. does not have a contractual or other right to his or her. [stock redemption] | taxation of stock redemption in a c corporation [report officer salaries] | where to report officer salaries for an s corp.

Tax consequences of liquidating a utma

an ordinary loss instead of a capital loss on the disposition or worthlessness. the company was “administratively dissolved” some time after, for example, effective january 25, 2008, due to its failure to timely pay state franchise taxes. partially completed must include in income a percentage of the profit.**when a complete liquidation is followed by a pre-arranged transfer of all or part of its essential operating assets to a second (almost always newly-created) controlled corporation, the steps may be “collapsed” and treated as a single, unitary transaction which bears an unmistakable resemblance to a reorganization. that reason, it is well-settled that a liquidation can occur without a formal or legal dissolution and, now, thanks to ltr 200806006, we also know that a dissolution—which does not give rise to an automatic transfer of the dissolved corporation’s assets to its shareholders—also does not give rise to, in and of itself, a complete liquidation. not intended as an exhaustive list, but rather, as guidance to the identification. big bets and real risks: brexit's effect on business sectors. separately on each asset that is distributed in liquidation equal to. should be alert to the possibility of recapturing depreciation, investment. (see bittker and eustice, federal income taxation of corporations and shareholders at para. the last substantial distribution can be used only if, at that time, the amount of the final distribution is both de minimis and determinable with “reasonable certainty. a sale can be accomplished by either transferring all of the corporate assets or transferring all of the stock. it is considered terminated, the company would have been viewed as having completely liquidated, and both it and its shareholders would have experienced the tax consequences attendant to the situation. When a firm or corporation distributes to its shareholders all of its assets, both tangible and intangible, and ceases doing business, the IRS says there is a taxable distribution of its intangible goodwill. following are exceptions to the general rules:Costs of reorganization - if the liquidation is related to a reorganization,The expenses allocated to the cost of the reorganization are not deductible. in the normal course of business (before the adoption of the plan of. every small business is different, and the tax consequences depend on several factors. conversely, the stockholders record a loss (also, almost always a capital loss), if the net distribution is less than their adjusted basis in the stock surrendered in the transaction.-2(c) of the tax code, “…legal dissolution is not required…” what’s more, a related revenue rule (rev. that irc section 301 will not apply to a liquidating distribution. these taxes can be significant if the corporation and shareholders own primarily intellectual property, such as a secret recipe, that had no value at the time the company was established but is now worth millions as a trade secret. transaction is treated somewhat differently if a shareholder owns more than one block of stock, and receives a series of distributions in complete liquidation. for his or her stock, also recognizes a gain (irc. in addition, the dissolution and reincorporation will not affect its shareholders’ bases and holding period in its stock. references (3) university of illinois farmdoc: income tax consequences of changing business entityhenry & horne, llp: tax considerations of selling your business – c corporationinternal revenue services: examining officers guide – corporate liquidations/dissolutions resources (2) tax and business professionals: to c or not to c? from such an agreement is a benefit that can be. the distribution of an installment obligation in a corporate liquidation.

Tax implications of liquidating a corporation

fair market value of the property received in excess of. a c corporation pays corporate income tax on its earnings, and then shareholders pay personal income tax on distributions. corporation in existence during any portion of a taxable year is required. and any other recapture provisions that may be applicable to a liquidating.. both the purchaser and the shareholder(s) must elect irc section. corporate reorganizations or other schemes which have been devised for. recognition - examiners should be aware of any assets being contributed. partial liquidations per irc section 302(b)(4) and income tax regulations. amount of gain reportable by the shareholders under irc section 1001(a). s corporation return, which flows-through to the old shareholder(s). a c corporation meeting the irs qualifications may apply for s corporation status. billed, then the receivables must be taxed to the corporation [see j. to no irc section 331 gain or loss at the shareholder level. s corporation structure accounting for an s corporation shareholder buyout how to transfer a trust deed to a guardian conservator subchapter s corp restrictions how is passive income taxable to an s corporation shareholder? state law allows a dissolved company to own assets, the dissolution, unless accompanied by an actual conveyance of the entity’s assets to its shareholders, will not give rise to a liquidation. value not appearing in the asset accounts because they were expensed or.. 142 ) states that “…where a corporation ceases business operations, has retained no assets, has no income, and has actually liquidated, there is in effect a de facto dissolution, even though the corporation has not been formally dissolved…”. to irc section 336(a), a corporation will recognize gain or. the directors should adopt a resolution recommending liquidation, and the shareholders should adopt a resolution approving the recommendation. each of these actions produces potentially taxable events at the corporate and individual shareholder levels. be aware of potential irc section 1245 recapture at the time of conversion. selling a c corporation selling a corporation involves both stock and the company's assets. [calculate federal income tax liability] | how to calculate federal income tax liability of a c corporation [tax treatment] | tax treatment of debt distributed to shareholders in a corporate liquidation also viewed [company use] | why would a company use liquidating dividends? a corporation is not in existence after it ceases business. nothing stated or implied in this article should be construed to be legal, tax, or professional advice. there a continuing purpose to terminate corporate affairs and dissolve? instead of taxing both the corporate earnings and the distributions to the shareholders, s corporation income is not taxed on the corporate level.

Tax Consequences of Distributions from C Corporations

Tax Considerations of Selling Your Business - C Corporation

.assignment of income doctrine - this provides that the rights. as well as money in exchange for the capital stock. without an employment agreement or noncompete covenant,Client goodwill attributable to a shareholder’s personal. been successful in establishing that such arrangements constitute a reorganization. but for tax purposes, the defining line can make a big difference.. the court stated that:The determination as to whether and/or when a corporation has liquidated. under state law or lack thereof will not be controlling. accordingly, the continuation of existence, after dissolution, may well depend on whether the governing state law provides that a dissolved corporation can still own assets. if a corporation was not in existence throughout an annual. assignment of income or clear reflection of income doctrines should be. my account | check order status | contact us | our satisfaction guarantee speak to a customer care specialist: (888)552-4921 forming your business llc (limited liability company) incorporation (s-corp, c-corp) nonprofit sole proprietorship general partnership lp (limited partnership) llp (limited liability partnership) compare s-corp, c-corp, llc not sure which one is right for you? as of 2010, the federal tax rate for long-term capital gains was 15 percent, a rate favorable to those whose stock increased in value after purchase. requirements of irc section 1244 stock are as follows:The stock was issued by a domestic corporation which was a. from the tax court’s reasoning when a distribution of. as part of every liquidation, state and federal income, payroll and capital gains taxes must be paid at both the corporate and individual levels. if the stocks are transferred instead, this will result in a capital gains tax on any appreciated value in the stocks at both the corporate and shareholder level. following are some potential issues which might be encountered by. sales of stocks produce either a capital loss or gain." this type of tax treatment means that income and gains on property are taxed first at the corporate level and then again at the individual shareholder level for any dividends received. SUMMARY THE IRS SAYS DISTRIBUTIONS of customer-based intangibles to shareholders are taxable. assets - a taxpayer may advance the position that contingent. the shareholders are also taxed on the transfer, provided the assets exceed the value of the stocks traded. for any irregularities/unusual items:A resolution adopted by directors recommending corporate liquidation;. held that it isn’t if a noncompete agreement between the. light of the requirement that an accounting method must clearly reflect. cpa journal: converting a corporation to an llc photo credits comstock/comstock/getty images suggest an article correction related searches more articles [deduct final expenses] | how to deduct final expenses after a dissolution of a c corporation [federal income tax return] | does a corporation have to file a federal income tax return when it has no sales? the directors then prepare and adopt a resolution giving the board and the company's officers the authority to execute the liquidation.

C Corporations

as there’s a genuine business purpose in taking such. 4 [dissolve] | how to dissolve and liquidate an s corporation forming a c corporation was once the only way the owner of a small business could shield himself from the debts and liabilities of the company. of redeeming stock - irc section 162(k) specifically provides that. possible reasons requiring liquidation are the closing or sale of the business or changing the business structure to provide more favorable tax treatment.“clients or customers belong to the employer and not the. liquidation of the assets will result in a tax on the gains, similar to that observed in changing business structure. is on the completed contract method and liquidates when a project is.. the proper character of gain from a liquidating s corporation. to its shareholders all of its assets,Both tangible and intangible, and ceases doing. gain is calculated by subtracting the value of the property transferred from its worth at the time it was acquired. the tax treatment of the shareholders is governed by the tax code’s section 331(a), which provides that amounts distributed in complete liquidation, “shall be treated as in full payment in exchange for the stock. applies a three-pronged test to determine whether a complete liquidation. the s corporation acquires an installment obligation from the sale. section 346(a) allows for a series of distributions pursuant to. eventually, company officers learned of their plight and reincorporated the business in the same state. the election is made on form 8023 and is due the 15th day of the. depreciation is recaptured on the basis of the fair market value of the assets. the tax court, on the other hand, the answer is that it. a large nondeductible item could then liquidate, and ultimately reduce. as part of the conversion, the assets owned by the corporation must first be transferred to the shareholders in exchange for stock. in the ruling, a corporate taxpayer had been incorporated in a state on a particular date, let’s say january 19, 2007. the s corporation has an installment obligation from the sale of an. however, in some cases, complete liquidation need not be accompanied by a formal or legal dissolution of the corporation. the other hand, if the corporation was formerly a c corporation,There may be a built-in gains tax to the s corporation on the appreciation., a gain on disposition should be computed on the corporate return. subchapter s, all provisions of subchapter c (dealing with c corporations). effecting a complete or partial liquidation, the costs should be classified.

Cross Species Conversions and Mergers

ordinary loss pursuant to irc section 1244 shall not exceed:0,000, in the case of a husband and wife filing a joint return. » speak to an attorney » customer care related articles how to complete business paperwork for an llc or corporation what is an llc 1065 filer? plan of liquidation to be treated as being part of a complete liquidation. how to liquidate a general partnership how do i file s-corp taxes in georgia? be treated as continuing as a corporation for certain limited purposes. fine line exists between definitions of a corporate liquidation and dissolution. examining process next article: how to complete business paperwork for an llc or corporation this article was created by and is owned by leaf group ltd. it isn’t clear how the tax court would treat. many owners choose this option because the capital gains tax rate is lower than the rate applied to the sale of appreciated assets. 336 - gain or loss recognized on property distributed in complete. of issuing/reselling stock - a corporate taxpayer may generally. shareholders might prefer to sell their stock, but buyers might be more interested in the assets. planning requires cpas to examine existing employment agreements with shareholder-employees. comstock/comstock/getty images related articles 1 how to close down a c-corp 2 [cash liquidation distribution] | what is 1099 cash liquidation distribution? witness the situation described in recent letter from the internal revenue service (ltr 200806006, november 7, 2007), which addresses a seeming anomaly related to the tax code. recognize gain upon a distribution of appreciated assets in liquidation. this liquidation results in an initial tax on the corporation for any gains on the property. there is any question involving state law on a dissolved, liquidated,Or merged corporation, and/or the validity of a statute extension or power-of-attorney,An opinion should be promptly requested from area counsel. the employment agreement,Per se, does not make the client corporate. references for corporate liquidations/dissolutions are:Irc 302(b)(4) - redemption from noncorporate shareholder in partial liquidation. should be aware of the possibility of a liquidating corporation.. if stock qualifies as irc section 1244 stock then the shareholder can. information to be included by taxpayers in submitting ruling requests. is then a deemed distribution of the sales price in liquidation of the. if irc section 336(a) does not serve as an argument that all. series of distributions in liquidation, gain is recognized once all of the. the working assets could be a device to recognize losses.

На главную страницу Sitemap