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Transfer of Assets Internal Revenue Service Reorganizations

Rivkin Radler LLP

Trust Beneficiary Engages In Like Kind Exchange Using Trust Property

Rivkin Radler LLP on

It is a basic principle of the income tax that the gain or loss realized by a taxpayer from the conversion of property into cash, or from the exchange of property for other property that differs materially in kind from the...more

Cadwalader, Wickersham & Taft LLP

IRS Issues Taxpayer-Favorable Debt Workout Ruling

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

Lowndes

Beware Transferee Liability

Lowndes on

One of the great features of corporations is that liability in the corporation generally does not extend to its shareholders, including tax liability. Like any rule, though, there is almost always an exception. In this...more

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