For the 28th week of 2013, the IRS published the following Private Letter Rulings relating to international taxation. PLR 201328003 - Multiple cash transfers disregarded as a circular flow of cash (cash contribution by Foreign Parent into Newco, followed by Newco cash purchase of Oldco Subsidiaries, followed by Oldco distribution of cash to Foreign Parent). Transaction treated as though Oldco distributed shares of Subsidiaries to Foreign Parent and Foreign Parent then contributed Subsidiaries into Newco....
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