Tax deferred reorganizations involving U.S.-owned foreign corporations may be currently taxable under certain circumstances.

Question

Quizplus · Accepted Answer

Tax deferred reorganizations involving U.S.-owned foreign corporations may be currently taxable if certain conditions are met, such as if the reorganization does not qualify for deferral under the applicable section of the Internal Revenue Code or if the foreign corporation is deemed to be a controlled foreign corporation (CFC) under the tax rules. It is important to consult with a tax professional to determine the tax implications of any proposed reorganization.

Tax Deferred Reorganizations Involving U