Extract to table

The statutory text of § 367(a)(1) provides that a foreign corporation shall not be considered as a corporation for purposes of determining the extent to which gain shall be recognized on certain enumerated transfers

The feeder/master structure creates indirect partners whose shares of liabilities must be determined under the tiered partnership rules, and the interaction of these rules with the netting provision of Treas

72 billion in built-in gain, which must be tracked under IRC § 704(c)