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IRS issues Memorandum on cross-border reorganization transactions

|Approved Changes|United States
United States

The Associate Chief Counsel (Corporate) of the US Internal Revenue Service (IRS) has issued a Memorandum that discusses the US tax consequences of cross-border restructuring transactions undertaken by a taxpayer's affiliated group.

The restructuring occurred in two stages a few months apart. The first stage (the "F Reorganization") included a series of transactions that the taxpayer treated a…

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