The Revitalization of Foreign-to- Foreign F Reorganizations Under U.S. Law, Tax Notes International, Volume 88, No. 6, November 6, 2017.
In this article, the author discusses the final regulations for U.S. F reorganizations, focusing on the use of foreign-to-foreign F reorganizations to achieve non-U.S. business planning goals (including non-U.S. tax planning) while avoiding adverse tax consequences under U.S. federal law.
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Authored by Kristin E. Konschnik