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How to Document a Tax-Free D Reorganization With a Split-Off Logo aicpa

  Steve Drucker, CPA, MST |   Free |   AICPA |   01 Jan 2017 |   Tax Adviser Magazine

For a number of years, the Internal Revenue Service has not issued rulings on whether a split-off D reorganization qualifies for tax-free treatment. Nonetheless, taxpayers undertaking these transactions must document that they meet the requirements for this treatment. This article presents a sample memorandum that can be used by taxpayers if the IRS challenges their treatment the transaction.

Topics covered:
  • Tax: Technical: C corporation income taxation : Formation, liquidation & reorganization, Intermediate