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
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But businesses should remain flexible when choosing between internal and external resources to handle added ViDA complexity, ITR’s Indirect Tax forum also heard
The new managing director of R&D tax relief consultancy ForrestBrown tells ITR about his priorities for the business, where he’s focusing his time and what makes tax cool