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Technical

Uncertainty Surrounding Back-to-Back F Reorganizations Logo aicpa

  Evan Adams, J.D., LL.M. |   Free |   AICPA |   01 Feb 2017 |   Tax Adviser Magazine

An F reorganization is tax-free if it is a mere change in identity, form or place of organization of one corporation, no matter how that is achieved. Recently issued regulations explain how these rules are supposed to apply in back-to-back reorganizations that implicate the step transaction doctrine.

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

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