Overview
Bloomberg BNA and Tax Notes quoted Steptoe tax partner Lisa Zarlenga on F reorganizations regulations. The articles discuss how the final F reorganization regulations may allow taxpayers to close a tax year for a corporation by simply failing the formalistic requirements of the rules, which turn off the step transaction doctrine. F reorganizations allow corporations to transfer assets from one entity to another if there is only a “mere change” and all the assets, shareholders and tax attributes stay the same. The articles feature comments from Ms. Zarlenga that were made during a March 4 panel presented at the Federal Bar Association's Tax Law Conference 2016 in Washington, DC.
Ms. Zarlenga tells Tax Notes that she thinks that kind of planning may work. "The regs are very form driven, and so one could conclude from the regs that if you don't meet the form, it's not an F reorganization," she says.
The full articles can be read at Bloomberg BNA and Tax Notes (subscriptions required).
