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

Indirect Tax

ITR set for Indirect Tax Forum 2026 in Amsterdam

The event comes at an important moment for professionals dealing with practical realities related to this practice area

Sam Sholli, June 12 2026

Direct Tax

A taxing week: the Germans are all at sea over PE

Germany’s dogmatic restriction of third-party investment in tax advisory firms will only serve to slow down innovation and access to justice

Aled Griffiths, June 12 2026

Direct Tax

This week in tax: Watchdog warns Ireland over corporate tax spending

The Irish government has been told that it’s spending too much of its corporation tax receipts and should instead focus on running bigger surpluses; plus, the IRS is set to merge tax practitioner offices

Sam Sholli, June 12 2026

Transfer Pricing

‘Gamechanger’: ICTS system will be boon for HMRC, says Ryan TP principal

A company risks double taxation, penalties and inquiry cost if it submits a form with anomalies under the new system, Asker Ali also tells ITR

Sam Sholli, June 11 2026

Transfer Pricing

Money exchange abroad with business data ai technology. Concept for digital money transfer banking and world economic financial investment trading. 3D illustration banner.

Transfer pricing automation in ERP systems: traps for compliance

Arindam Mitra and Robin Hart examine how aggregate TP rules clash with transaction-level customs rules, creating compliance risks and requiring granular, SKU-level pricing strategies

Arin Mitra, June 11 2026

Direct Tax

KPMG gears up for hearing amid confidential leaks scandal

The scandal has come just three years after the PwC tax leaks controversy and has prompted KPMG’s Australian chief executive to resign

Sam Sholli, June 10 2026

Direct Tax

r and d - acronym from wooden blocks with letters. background hands on a laptop with blur. business concept.

Capital v revenue in R&D – isolated concerns or a future battleground? Part one

In the first of a two-part series on capital v revenue in R&D, Jayne Stokes explores these key concepts and where UK companies need to tread carefully

Jayne Stokes, June 09 2026

Direct Tax

A&M Tax continues Europe push with Sweden launch

Magnus Pantzar is set to join as managing director after spending nearly a decade as EQT’s global head of tax

Sam Sholli, June 08 2026

Direct Tax

Pillar two criticism fair despite filing penalty waiver: BDO tax leader

The OECD’s project was up for debate as Matt Williams spoke to ITR following BDO’s tax strategist survey, which uncovered increased complexity and costs among multinationals

Sam Sholli, June 08 2026

Direct Tax

A taxing week: Ryan’s Svalner Atlas deal shows that size does matter

The recent spree of firm mergers and acquisitions proves that geographic scale is the name of the game

Tom Baker, June 05 2026