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Inbound §332 Liquidations & Inbound Asset Reorganization

Volume 3 No 5    /    Read Article

By Rusudan Shervashidze and Andrew P. Mitchel

Rusudan Shervashidze and Andrew P. Mitchel continue their examination of U.S. tax rules applicable to cross-border reorganizations, formations, and liquidations. This month, they review rules applicable to the liquidation of a wholly-owned domestic subsidiary corporation into its foreign parent corporation. Also discussed is the toll charge imposed on asset reorganizations that result in the domestication of a foreign subsidiary.    See more →