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Corporate Taxes › Foreign Corporations › Private Letter Rulings

Bilzin Sumberg

Ruling Demonstrates Potential for Inversion Rules to Apply in Inbound Structures

Bilzin Sumberg on

In Private Letter Ruling 201432002 (the “PLR”), the IRS ruled that a foreign-to-foreign “F” reorganization did not implicate the Section 7874 anti-inversion rules. As a result, a foreign corporation (that was 100 percent...more

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