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tax-free “D” corporate reorganization

IRS Revokes Prior Ruling, Upholds Tax-Free Exchange & Nonrecognition Treatment

IRS Revokes Prior Ruling, Upholds Tax-Free Exchange & Nonrecognition Treatment

Rev Rul 2015-9, 2015-21 IRB   IRS has issued a Revenue Ruling in which it concluded that a transaction involving a series of stock transfers among a domestic parent and its foreign subsidiaries, and the liquidation of several existing subsidiaries, qualified as a tax-free Code Sec. 351 exchange followed by a series of type D […]

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PLR: Cross-Chain Sale Failed to Qualify as a “Type D” Reorganization

PLR: Cross-Chain Sale Failed to Qualify as a “Type D” Reorganization

PLR 201419013. In a Technical Advice Memorandum (TAM), IRS has concluded that a taxpayer’s “cross-chain sale” didn’t qualify as a “Type D” reorganization under Code Sec. 368(a)(1)(D) because it failed to meet the control and distribution requirements of such a reorganization. Background. The Code provides general nonrecognition treatment for reorganizations specifically described in Code Sec. 368(a). Under […]

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Spin-off to limit potential environmental liabilities qualifies as D reorganization

Spin-off to limit potential environmental liabilities qualifies as D reorganization

IRS has privately ruled in Private Letter Ruling 2013-29005, that a spin-off to shield a corporation from potential environmental liabilities will qualify as a tax-free “D” corporate reorganization. In reaching this result, IRS cautioned that it had not verified and made no determination concerning a number of issues, which could be addressed in the audit […]

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Meet Paul Raymond

Meet Paul Raymond

Mr. Raymond is a sought after speaker in tax controversy law by many attorney, accountant, and business groups and at the request of the Internal Revenue Service, has presented programs at the IRS Nationwide Tax Forum, attended by tax professionals throughout the United States.

Additionally, he continues to be an active member in the Section of Taxation, American Bar Association, where he was the Past Chair of the Employment Taxes Committee.

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Member CA Bar Member Orange County Bar US Tax Court Attorney