Reorganizations, Intercompany Debt Addressed in Private Letter Rulings

The Internal Revenue Service in private letter rulings regarding corporate reorganizations released April 23 addressed transactions constituting “A” and “D” reorganizations, as well a transaction undertaken by…

ANALYSIS: Separate Return Limitation Year Rules, ‘Hook Stock’ Among Items Addressed in Recent IRS Corporate Private Letter Rulings of Note

Jasper L. Cummings, Jr. of Alston & Bird LLP examines recent private letter rulings of note involving corporate taxpayers. He examines PLR 201003012′s demonstration of…

IRS Finds No Foreign Base Company Sales Income from Transactions involving Bifurcated Manufacture of Products

The Internal Revenue Service in Private Letter Ruling 201002024, released Jan. 15, applied the tax rate disparity test in determining that…

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

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…