IRS PLR: Corporate Reorganization Transaction Rulings Issued (§368)

The IRS issued 17 rulings on certain federal income tax consequences of a series of transactions in a corporate reorganization. (1) Two rounds of contribution and of distribution, followed by the liquidation of “Distributing,” will be a “reorganization” within the meaning of tax code Section 368(a)(1)(D) and each involved party — Distributing and two controlled companies respective to the contribution rounds — a “party to a reorganization” within the meaning of Section 368(b). (2), (3), (8), (9), (10) No gain or loss will be recognized by Distributing, Controlled 1, or Controlled 2 on either contribution, or by ...