US inbound update: Reorganization ruling has international ramifications

November 21 2004

Revenue Ruling 2004-83 holds that the sale of one subsidiary to another subsidiary followed by the liquidation of the purchased subsidiary as part of an integrated plan qualifies as a reorganization under Internal Revenue Code (IRC) section 368(a)(1)(D) and is not subject to IRC section 304, whether or not the subsidiaries are part of a consolidated group

Unlock this content.

The content you are trying to view is exclusive to our subscribers.

To unlock this content:

Take a Free Trial or Login

Topics

more across site & shared bottom lb ros

More from across our site

Transfer Pricing

EY hires four senior PwC tax partners in Australia

Among those joining EY is PwC’s former international tax and transfer pricing head

Sam Sholli, January 15 2026

Direct Tax

Grant Thornton UK adds eight tax partners

The UK firm made the appointments as it seeks to recruit 160 new partners over the next two years

Sam Sholli, January 14 2026

Direct Tax

Irvine, CA, USA - May 6, 2022: Exterior view of Baker Tilly's office in Irvine, California. Baker Tilly US, LLP is a public accounting and consulting firm headquartered in Chicago, Illinois.

Baker Tilly International records 31% tax service line growth

The network’s tax service line grew more than those for audit and assurance, advisory and legal services over the same period

Sam Sholli, January 14 2026

Direct Tax

Base_of_two_pillars_at_Viborg_Katedralskole_320x215

‘Sigh of relief’ for multinationals after pillar two side-by-side agreement

The deal is a ‘real win’ for US-based multinationals and its announcement is a welcome relief, experts have told ITR

Sam Sholli, January 13 2026

Direct Tax

Washington DC Capitol view on cloudy sky background

Ex-US Supreme Court advocate stands trial over tax affairs

Tom Goldstein, who is now a blogger, is being represented by US law firm Munger, Tolles & Olson

Sam Sholli, January 12 2026

Direct Tax

A taxing week: Tax need not be just about revenue for governments (yes, seriously!)

In looking at the impact of taxation, money won't always be all there is to it

Sam Sholli, January 09 2026

Direct Tax

Australia’s TPB welcomes Andrew Orme as new secretary

Australia’s Tax Practitioners Board is set to kick off 2026 with a new secretary to head the administrative side of its regulatory activities.

Tom Ravlic, January 09 2026

Direct Tax

This week in tax: Ireland records €8.6 billion rise in tax receipts

Ireland’s Department of Finance reported increased income tax, VAT and corporation tax receipts from 2024; in other news, it’s understood that HSBC has agreed to pay the French treasury to settle a tax investigation

Sam Sholli, January 09 2026

Transfer Pricing

IKEA announces intention to dispute A$171m ATO tax claim

The Australian Taxation Office believes the Swedish furniture company has used TP to evade paying tax it owes

Sam Sholli, January 07 2026

Indirect Tax

This month in indirect tax: UK supermarket loses VAT court battle

Supermarket chain Morrisons is facing a £17 million ($23 million) tax bill; in other news, Donald Trump has cut proposed tariffs

Sam Sholli, January 07 2026