Subscribe to the Tax Headline RSS feed | Subscribe to the Tax Headline feed via EmailANALYSIS: Intragroup Reorganizations Addressed in IRS Corporate Public Letter Rulings of Note
March 22, 2010 in Daily Tax Report · Leave a Comment
Jasper L. Cummings, Jr. of Alston & Bird LLP examines three recent letter rulings that address recurrent issues of rescission, liquidation-reincorporation, the recipient of the reorganizing corporation’s tax attributes, corporate reshufflings after a spin-off, the avoidance of Section 355(e) problems, movement of consolidated group members within the group, and the unavailability of the Section 336(e) election before the proposed regulations are finalized. Also, Cummings notes, two of the three rulings involve hindsight tax planning—in one it worked and in another it did not…
