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Asset Transfer Internal Revenue Service Internal Revenue Code (IRC)

Cadwalader, Wickersham & Taft LLP

New Proposed 'Killer B' Regulations Reduce Compliance Sting

On October 5, the U.S. Treasury released long-awaited proposed regulations regarding inbound cross-border reorganizations, implementing (with modifications) policies that had been announced in 2014 and 2016 notices. These...more

Perkins Coie

Don’t Burst My Bubble! IRS Provides Clarity for F Reorganizations

Perkins Coie on

Recently, the Internal Revenue Service issued final regulations addressing reorganizations, commonly referred to as “F reorganizations,” under Section 368(a)(1)(F) of the Internal Revenue Code (the Code). F reorganizations...more

Eversheds Sutherland (US) LLP

To the Direct Acquirer Belong the Tax Attributes: Proposed Regulations Modify the Definition of Acquiring Corporation for Purposes...

On May 7, Treasury and the IRS published proposed regulations addressing which corporation succeeds to the tax attributes of another corporation that transfers assets in an acquisitive asset reorganization described in IRC §§...more

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