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IRS Rules Conversion of Foreign Subsidiary, Transfer of Assets Will Be ‘F’ Reorganization

January 11, 2010 in Daily Tax Report · Leave a Comment 

The Internal Revenue Service ruled in Private Letter Ruling 201001002, released Jan. 8, that a corporate reorganization transaction proposed by the parent of a consolidated return group involving the conversion of a foreign subsidiary to a new entity and transfer of its assets to a new corporation will qualify as…

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