The Internal Revenue Service’s new private letter ruling (PLR) concerned a domestication of a Foreign Parent corporation under U.S. ownership—with a few notable twists. First, the PLR applied a substance-over-form analysis to...more
7/23/2024
/ Corporate Conversions ,
Corporate Restructuring ,
Domestic Corporations ,
Foreign Corporations ,
IRS ,
Parent Corporation ,
Private Letter Rulings ,
Reorganizations ,
Share Classes ,
Stock Issuance ,
Stock Sale Agreements ,
Subsidiaries ,
Tax-Free Exchanges
“In terrorem” or anti-abuse provisions often receive a lack of judicial and administrative interpretation. Section 163(l) of the Code, enacted in 1997, is no exception, so that even now certain fundamental questions relating...more