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

The IRS issued 32 rulings on certain transactions proposed (collectively, the “Proposed Transaction”) pursuant to the reorganization of an international corporate group. (1, 18) A U.S. corporation’s (“U.S. Distributing”) contribution of interests in a domestic limited liability company (one of several formed for purposes of the Proposed Transaction) to a U.S. controlled corporation, followed by U.S. Controlled’s split-off, will be a reorganization under tax code Section 368(a)(1)(D), as will a foreign parent’s contribution of all of U.S. Controlled stock to an external controlled corporation in exchange for External Controlled stock, followed by that controlled’s spin-off (distribution to Foreign ...