Gain a better understanding of the requirements of an F reorganization.
Final regulations promulgated by Treasury and the IRS in 2015 provide a comprehensive set of rules regarding 'F' reorganizations. This topic will examine those regulations in detail, including the requirements to qualify as an 'F' reorganization, the impact of related redemptions and distributions, the application of the step transaction doctrine, and overlap rules with respect to other reorganizations under section 368. The material will provide examples that illustrate the operation of the rules in the regulations and discuss transaction planning considerations with regard to 'F' reorganizations.
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