PLR Addresses F Reorganization Stock Transfer

The Internal Revenue Service addressed the transfer of U.S. real property holding company stock in an inbound F reorganization and considered requests for extensions of time and similar relief in recent private letter rulings.

In PLR 201321007, IRS considered a foreign parent corporation’s plan to reincorporate into the United States in a Section 368(a)(1)(F) reorganization, ruling the parent will recognize no gain or loss on the transfer of stock of its subsidiary U.S. real property holding corporation to the new U.S. parent in exchange for stock under Sections 361(a) and 897(e), nor will it recognize gain or loss ...