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International Tax Blog - New and Interesting International Tax Issues


Situational Chart of Rev. Rul. 89-103 - Stapling of Interests Triggers Inbound "F" Reorganization

2013-09-17

Below is a chart of Rev. Rul. 89-103 in which the IRS held that a stapling of foreign and domestic stock interests triggers a deemed inbound "F" reorganization for the foreign entity.

The chart can be viewed as a PDF file here: Rev. Rul. 89-103

89-103

Tags: 368 Corporate Reorgs, Charts - Situational Charts