The Resource Conducting business in the United States through a corporation "operating on a cooperative basis"

Conducting business in the United States through a corporation "operating on a cooperative basis"

Label
Conducting business in the United States through a corporation "operating on a cooperative basis"
Title
Conducting business in the United States through a corporation "operating on a cooperative basis"
Creator
Subject
Language
eng
Summary
Article on private letter ruling LTR 20102408 which addresses issues arising from a combination of three US corporations owned by eight corporations, all of which were foreign. The combination was structured as the merger of two of the corporations into the third, and the IRS ruled that the merger qualified as a Code Sec. 368(a)(1)(A) reorganization and is treated as a cooperative under subchapter T of the Code. The author discusses some tax issues that arise when a US cooperative has foreign members
Citation source
In: International tax journal. - Chicago. - Vol. 37 (2011),
http://library.link/vocab/creatorName
Benson, G.W
Geographic coverage
International
Language note
English
http://library.link/vocab/subjectName
  • private ruling
  • merger
  • reorganization
Label
Conducting business in the United States through a corporation "operating on a cooperative basis"
Instantiates
Publication
Label
Conducting business in the United States through a corporation "operating on a cooperative basis"
Publication

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