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Domestication of foreign corporation ruled a tax-free reorganization

In PLR 201126023 the IRS has ruled that (1) the domestication of a foreign corporation would be considered a reorganization under Code Sec. 368(a)(1)(F); (2) such domesticated company could elect to be considered an S corporation on the date it became domesticated; and (2) the trusts that wholly-own the domesticated corporation were eligible to elect to be treated as electing small business trusts (ESBTs).

Source: International Tax Updates on Checkpoint Newsstand

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The attorneys at The Beliveau Law Group provides legal services for estate planning (wills and trusts), Medicaid (planning and applications), probate (estate and trust administration), business law (formation and operation), real estate (residential and commercial), taxation (federal and state), and civil litigation (in connection with these practice areas). The law firm has offices and attorneys in Naples, Florida; Boca Raton, Florida; Danvers, Massachusetts; Waltham, Massachusetts; Quincy, Massachusetts; Manchester, New Hampshire and Salem, New Hampshire.

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