LB&I International Practice Service Transaction Unit

may liquidate under Internal Revenue Code (IRC) section 332 into its sole owner U.S. S/H . Given the general rule that U.S. tax on the foreign corporation’s earnings is def erred, an inbound (I/B) liquidation of a FC under IRC 332 could enable the earnings to escape U.S. taxation at the corporate-level.

  Liquidation, Inbound