Edward Tanenbaum The Advice Memorandum 2007-006 is generic legal advice from chief counsel to the IRS field, assuring the field that a domestic corporate purchaser of a foreign target eligible entity (treated as a default corporation) can make a section 338(g) election and step up the basis of the target's assets, despite the fact that no US tax will be paid, and whether or not the election is extended to a US subsidiary of the target. The target was irrelevant for US tax purposes prior to the purchase, meaning generally that it had no US owners or business.
April 30 2007