The US IRS on September 21 released final regulations regarding the qualification of a transaction as an F reorganization under section 368(a)(1)(F) by virtue of being a mere change of identity, form, or place of organization of one corporation.
The regulations generally adopt the provisions of 2004 proposed regulations not previously adopted in the 2005 regulations, with some changes.
The Service also finalized without substantive change 1990 proposed regulations on outbound F reorganizations.
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