The IRS has finalized its regulations on Section 368(a)(1)(F) reorganizations. An F reorganization is characterized as a mere change in the identity, form, or place of organization of one corporation.
The final regulations provide clarity as to what other changes can occur before, during or after the mere change in identity, form, or place of organization without jeopardizing the tax-free qualification of the reorganization. The regulations also address the treatment of an outbound F reorganization.
The regulations apply to transactions occurring on or after September 21, 2015.
