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Reincorporations in spinoffs

  • Alston & Bird LLP
  • -
  • USA
  • -
  • June 13 2011

You will rely on section 355 for nonrecognition, but here you also must rely on section 332 to make the liquidations tax free, without any liquidation-reincorporation problem

World’s longest letter ruling

  • Alston & Bird LLP
  • -
  • USA
  • -
  • November 1 2012

LTR 201240017 is the world’s longest letter ruling, 111 pages in PDF format