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Internal Revenue Service › Reorganizations › Distribution Rules

The United States Internal Revenue Service is a bureau of the United States Department of the Treasury. The IRS is charged with collecting revenue and enforcing the Internal Revenue Code.  
Hogan Lovells

IRS reduces barriers to redomiciliations

Hogan Lovells on

On August 19, the IRS released Notice 2025-45 (the “Notice”), announcing its plan to reduce barriers to certain redomiciliations. In particular, the IRS reduced barriers to redomiciliations by foreign publicly traded...more

Rivkin Radler LLP

Dividing the Multi-Family Corporation

Rivkin Radler LLP on

Sibling Rivalry- You have probably encountered family-owned corporations in which the founder’s offspring are involved in the business to varying degrees. They may even own some equity, typically having received such equity...more

Cadwalader, Wickersham & Taft LLP

IRS Issues Taxpayer-Favorable Debt Workout Ruling

Cadwalader, Wickersham & Taft LLP on

In PLR 202050014, the IRS ruled that a parent would not recognize taxable gain when its disregarded entity transferred a newly formed corporation’s stock to creditors in satisfaction of its debt pursuant to a “G”...more

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