IRS memorandum may offer taxpayer benefits relating to conversions of insolvent foreign corporations into partnerships

The Internal Revenue Service’s recently issued general legal advice memorandum (GLAM) should provide beneficial results to certain taxpayers that use a check-the-box election to convert an insolvent foreign corporation into a partnership.

Overview

Filed under:
USA, Insolvency & Restructuring, Tax, McDermott Will & Emery, Shareholder, Audit, Debt, Liability (financial accounting), Liquidation, Internal Revenue Service (USA)
Authors:
Michael J. Wilder
Location:
USA
Firm:
McDermott Will & Emery