Example: bankruptcy
LB&I International Practice Service Transaction Unit

LB&I International Practice Service Transaction Unit

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CFC to its U.S. S/H under IRC 355, I/B asset reorganization of a FC into a DC, or I/B IRC 351 transfer of assets or stock to a DC. In addition, IRC 367(b) may also apply to certain foreign-to-foreign (F-to- F) transactions which are also beyond the scope

  Transactions

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