30Jan
Mere Change?—“F” Reorganization Qualifies in Spite of Change in Plan
Former British Prime Minister Winston Churchill once said, “Plans are of little importance, but planning is essential.” Perhaps that quote is a tad strong to apply generally to corporate reorganizations under Section 368 of the Internal Revenue Code. Plans, after all, are very important—if not essential—in the context of corporate reorganizations. However, based on a recent Private Letter Ruling, the Internal Revenue Service (“IRS”) noted that the “plan of reorganization” requirement for an “F”...
By:
Freeman Law
Related
Head-on collisions are among the most dangerous of all car accidents. With the extreme forces involv...
Read More >
A federal district court in Pennsylvania held that it did not have subject matter jurisdiction to he...
Read More >
Over the past week we have seen an increasing number of employers grappling with the real, as oppose...
Read More >
Seyfarth Synopsis: In a recent Chief Counsel Memorandum (“CCM”), the IRS stated that on audit, age...
Read More >
At start-up, young technology companies focus entirely on their products, want to pitch and bring VC...
Read More >
Once a perk, the ability to work remotely is slowly becoming an expectation. Since 2005, the remote ...
Read More >