IRS issues Memorandum on cross-border reorganization transactions
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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