IRS PLR: Series of Transactions Considered Reorganization (IRC §368)

The IRS has published a private letter ruling on Sections 355, 361, and 368 making a determination on a proposed series of transactions by a publicly traded domestic corporation and common parent of a consolidated group, including that a certain contribution, together with a certain distribution, will be recognized as a reorganization within the meaning of Section 368(a)(1)(D) and Section 355. [PLR 202451015]

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