Below is a chart of Rev. Rul. 90-76 in which the I.R.S. addressed where gain must be recognized when foreign corporations liquidate, distributing U.S. Real Property Interests ("USRPIs").
The chart can be viewed as a PDF file here: Rev. Rul. 90-76
« Chart of PLR 201328003 - Deemed Distribution and Contribution with Circular Flow of Cash | Main | International PLRs for the 39th week of 2013 »
September 26, 2013
Chart of Rev. Rul. 90-76 - Foreign Corporations: Liquidating Distributions of USRPIs
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