Last year we blogged about PLR 201348011, where a U.S. corporation was not required to recognize gain on the distribution of its assets in liquidation to its foreign parent, except with respect to gain attributable to intangibles described in Code §936(h)(3)(B). The distributed property will continue to be used in a U.S. trade or business for ten years after the liquidation. Code §367(e)(2) and Treas. Reg. §1.367(e)-2(b)(2)(i).
We have created a situational chart of PLR 201348011, showing the entities before and after the liquidations. The chart is shown below and a PDF of the chart can be found here: