Last week the IRS released Rev. Rul. 2015-09 and Rev. Rul. 2015-10. In Rev. Rul. 2015-09, (1) a domestic corporation transferred all of the stock of its foreign operating subsidiary to its foreign holding company subsidiary in exchange for additional stock, (2) the foreign operating subsidiary and three foreign subsidiaries of the foreign holding company transferred substantially all of their assets to a newly-formed foreign subsidiary of the foreign holding company in exchange for stock... Read more →