Search results with tag "Section 368"
Instructions for Form 926 (Rev. November 2018)
www.irs.govrecapitalization described in section 368(a)(1)(E), or b. The U.S. person exchanges stock of a domestic or foreign corporation for stock of a foreign corporation under an asset reorganization described in section 368(a)(1) that is not treated as an indirect stock transfer under Regulations section 1.367(a)-3(d). 2. Generally, a domestic
Part I ISSUE
www.irs.govSection 368(a)(1)(A) provides that the term reorganization includes a statutory merger or consolidation. Pursuant to § 368(a)(2)(D), the acquisition by one corporation,
Section 368.—Definitions Relating to Corporate ...
www.irs.govSection 368.—Definitions Relating to Corporate Reorganizations . 26 CFR 1.368-2: Definition of terms. (Also §§ 351; 1.351-1, 301.7701-3.) Rev. Rul. 2015-10 . ISSUE . Is a transaction in which (1) a parent corporation transfers all of the interests in its limited liability company that is taxable as a corporation to its subsidiary (first ...