Handling restructurings and dispositions of a CFC
Article Abstract:
The authors outline international provisions that domestic corporate shareholders should consider when seeking to restructure or dispose of a controlled foreign corporation. Topics include transfers of assets and liability to a foreign corporation in exchange for voting stock, triangular C reorganizations, and sales of assets to an unrelated purchaser.
Publication Name: Corporate Taxation
Subject: Law
ISSN: 1534-715X
Year: 2001
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Section 368(a)(1)(F): the eye of the hurricane
Article Abstract:
The author outlines the Tax Code's generally accepted principles of corporate reorganizations and a related tax case, Resorts International. The question of whether an "F" reorganization meets the test of being above a mere change in identity, form, or place of the corporation is considered.
Publication Name: Corporate Taxation
Subject: Law
ISSN: 1534-715X
Year: 2001
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The application of section 367 to section 332 liquidations
Article Abstract:
The author explains how sections 367(b) and (e) of the Internal Revenue Code apply to liquidations of foreign corporations into domestic corporations, domestic corporations into foreign corporations, and foreign subsidiary liquidations into foreign parent corporations.
Publication Name: Corporate Taxation
Subject: Law
ISSN: 1534-715X
Year: 2001
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