To amend the Internal Revenue Code of 1986 to permit certain tax free corporate liquidations into a 501(c)(3) organization and to revise the unrelated business income tax rules regarding receipt of debt-financed property in such a liquidation.

Amends the Internal Revenue Code to allow certain tax-free liquidations from a closely held corporation into a tax-exempt organization. Revises unrelated business income provisions regarding property acquired subject to a mortgage with respect to such a liquidation.