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

Direct Tax

UK tax adviser ‘shocked’ at in-house costs criticism

It should be easy for advisers to be transparent about costs, Brown Rudnick partner Matthew Sharp said in response to exclusive ITR in-house data

Tom Baker, July 04 2025

Direct Tax

This week in tax: Donald Trump’s ‘big beautiful’ tax bill narrowly gets through Congress

The sprawling legislation phases out Joe Biden-era green tax incentives for businesses; in other news, the UK will reportedly maintain its DST despite US pressure

Sam Sholli, July 04 2025

Direct Tax

French Finance Act 2025: Major tax reform for management packages

New French legislation should create a more consistent legal environment for taxing gains from management packages, say Bruno Knadjian and Sylvain Piémont of Herbert Smith Freehills Kramer

Bruno Knadjian , July 03 2025

Transfer Pricing

‘TP litigation here to stay’: experts dissect South Africa ruling

The South Africa vs SC ruling may embolden the tax authority to take a more aggressive approach to TP assessments, an adviser tells ITR

Sam Sholli, July 02 2025

Indirect Tax

This month in indirect tax: compliance the top challenge for indirect tax, Thomson Reuters finds

Indirect tax professionals now rate compliance as a bigger obstacle than technology and automation; in other news, Italy approved a VAT cut on art sales

Sam Sholli, July 02 2025

Direct Tax

AI in tax: what’s the direction of travel?

AI-powered tax agents are likely to be the next big development in tax technology, says Russell Gammon of Tax Systems

Russell Gammon, July 01 2025

Direct Tax

Lewin Higgins-Green -- FTI Consulting.jpg

Five minutes with…Lewin Higgins-Green, FTI Consulting

FTI Consulting’s EMEA head of employment tax and reward tells ITR about celebrating diversity in the profession, his love of musicals, and what makes tax cool

July 01 2025

Direct Tax

Canada to scrap DST in bid to resume US trade negotiations

Canadian Prime Minister Mark Carney and US President Donald Trump have agreed that the countries will look to conclude a deal by July 21, 2025

Sam Sholli, June 30 2025

Direct Tax

PwC Australia’s government contract ban should be extended, senators say

The firm’s lack of transparency regarding its tax leaks scandal should see the ban extended beyond June 30, senators Deborah O’Neill and Barbara Pocock tell ITR

Tom Ravlic, June 30 2025

Transfer Pricing

DSTs as digital infrastructure: the tax challenges of emerging markets

Despite posing significant administrative hurdles, digital services taxes remain ‘the best way forward’ for emerging economies, says Neil Kelley, COO of Ascoria

Neil Kelley, June 27 2025