All material subject to strictly enforced copyright laws. © 2022 ITR is part of the Euromoney Institutional Investor PLC group.

US inbound update: Reorganization ruling has international ramifications

November 21, 2004
Share

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 article.

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

To unlock this article:

Take a Free Trial or Login

Tags

NewsUnited StatesDirect Tax
more across site & bottom lb ros

More from across our site

Vikas pic.jpg
Q&A: Siemens India Head of Indirect Tax talks GST
Vikas Garg talks to reporter Siqalane Taho about how regulation, technology and the goods and services tax has affected the manufacturing company.
Siqalane Taho, August 17, 2022
IT skills - 3.jpg
Tax technology skills crucial to meet compliance burden, say experts
A major shift is underway in tax as the profession transitions from a mostly accounting and finance sector to a hybrid industry that requires significant IT skills, say tax experts.
Siqalane Taho, August 17, 2022
IRS USA Government home page
US boosts IRS budget to improve IT and enforcement
The Biden administration is about to give $80 billion to the Internal Revenue Service to enhance the tax authority’s enforcement processes and IT systems.
Danish Mehboob, August 15, 2022
Loading energy of an electric car in Prague Czech republic
Global automakers about to lose important US tax credit
Audi, Porsche, and Kia say their US clients will face higher prices under the Inflation Reduction Act after the legislation axes an important tax credit for electric vehicle production.
Danish Mehboob, August 15, 2022
tutz-dias-brazil-2022-campaign.jpg
This week in tax: Brazil sets stage for VAT reform
This week Brazil’s former President Luiz Inacio Lula da Silva came out in support of uniting Brazil’s consumption taxes into one VAT regime, while the US Senate approved a corporate minimum tax rate.
Josh White, August 12, 2022
Amsterdam Netherlands dancing houses over river Amstel landmark
TP decree reinforces shift in Dutch tax policy
The Dutch TP decree marks a turn in the Netherlands as the country aligns its tax policies with OECD standards over claims it is a tax haven.
Leanna Reeves, August 11, 2022
Photo Gorka - Lexmark.JPG
Q&A: Lexmark VAT leader talks inflation and tax strategy
Gorka Echevarria talks to reporter Siqalane Taho about how inflation, e-invoicing and technology are affecting the laser printing firm in a post-COVID world.
Siqalane Taho, August 10, 2022
Tax data.jpg
Tax data security now high priority amid digitisation drive
Tax directors have called on companies to better secure their data as they generate ever-increasing amounts of information due to greater government scrutiny.
Siqalane Taho, August 10, 2022
Female hand with megaphone on white background
Last call to comment on Australia-India tax treaty
Incoming amendments to the treaty could increase costs on non-resident Indian service providers.
Danish Mehboob, August 08, 2022
Target shot opportunity dartboard performance how accurate can it be win looser miss fail flunk throw loss failure score on white background competition archery isolated 3d illustration
US corporate tax ‘not even close’ to pillar two
Experts say the proposed minimum tax does not align with the OECD’s pillar two regime and risks other countries pulling out.
Danish Mehboob, August 08, 2022
We use cookies to provide a personalized site experience.
By continuing to use & browse the site you agree to our Privacy Policy.
I agree