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
Source Url: https://www.jdsupra.com/legalnews/mere-change-f-reorganization-qualifies-6271926/
Related
Illinois is attempting to stay at the forefront of legislating the interaction between employment an...
Read More >
The Employee Benefits Practice is pleased to present the Employee Benefits Developments Newsletter f...
Read More >
Previously we introduced you to the FCPA and provided updates about the positive international trend...
Read More >
We’ve written about the “Future of Work” efforts recently undertaken by Congress – a series of h...
Read More >
In June, the U.S. Citizenship and Immigration Services (“USCIS”) posted a new version of Form I-9 ...
Read More >
The Basics - Representations and warranties insurance (R&W Insurance) protects a party from financi...
Read More >