The IRS has issued Revenue Ruling 2015-9 and Revenue Ruling 2015-10 which provide guidance regarding the application of section 351 and section 368(a)(1)(D) to certain corporate transactions. Revenue Ruling 2015-9 involves a transaction in which (1) a domestic corporation transfers all of the stock of its foreign operating subsidiary to its foreign holding company subsidiary in exchange for additional stock, (2) the foreign operating subsidiary and three foreign subsidiaries of the foreign holding company transfer substantially all of their assets to a newly-formed foreign subsidiary of the foreign holding company in exchange for stock of the new subsidiary, and (3) the subsidiaries that transfer their assets are liquidated.  The ruling holds that the transaction is properly treated as a transfer of the foreign operating subsidiary’s stock in an exchange governed by section 351 followed by reorganizations under section 368(a)(1)(D) and revokes Revenue Ruling 78-130. Revenue Ruling 2015-10 involves a transaction in which (1) a parent corporation transfers all of the interests in its limited liability company that is taxable as a corporation to a first tier subsidiary in exchange for additional stock, (2) the first tier subsidiary transfers all of the interests in the limited liability company to its subsidiary in exchange for additional stock, (3) the second subsidiary transfers all of the interests in the limited liability company to its subsidiary (a third tier subsidiary of the parent) in exchange for additional stock, and (4) the limited liability company elects to be disregarded as an entity separate from its owner for federal income tax purposes effective after it is owned by the third subsidiary.  The ruling holds that the transaction is properly treated as two transfers of stock in exchanges governed by section followed by a reorganization under section 368(a)(1)(D).