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Thursday, February 07, 2019 7:22:32 PM
Yeah the PLR for Bioamber and LCY does...
Give it a read
3 Sections of the Internal Revenue Code are covered.
Section 355 Distribution of Stock and Securities of a Controlled Corporation - Spin-Off
Section 361 Nonrecognition of Gain or Loss to Corporations - Certain Transfers to Creditors
Section 368 Definitions Relating to Corporate Reorganizations - Assets for Control of Transferee (Type "D")
https://www.irs.gov/pub/irs-wd/201851005.pdf
https://www.irs.gov/pub/irs-wd/201851_idx.pdf
Give it a read
3 Sections of the Internal Revenue Code are covered.
Section 355 Distribution of Stock and Securities of a Controlled Corporation - Spin-Off
Section 361 Nonrecognition of Gain or Loss to Corporations - Certain Transfers to Creditors
Section 368 Definitions Relating to Corporate Reorganizations - Assets for Control of Transferee (Type "D")
https://www.irs.gov/pub/irs-wd/201851005.pdf
https://www.irs.gov/pub/irs-wd/201851_idx.pdf
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