This site uses cookies to store information on your computer. Some are essential to make our site work; others help us improve the user experience. By using the site, you consent to the placement of these cookies. Read our privacy policy to learn more.


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