Extract to table

Capitalized terms used but not otherwise defined herein shall have the meanings ascribed to them in the PLR Request when filed

Section 367(a)(1) provides, in relevant part, that "[i]f, in connection with any exchange described in section 332, 351, 354, 355, 356, or 361, a United States person transfers property to a foreign corporation, such foreign corporation shall not, for purposes of determining the extent to which gain shall be recognized on such transfer, be considered to be a corporation

federal income tax purposes, a tiered partnership analysis is required to determine the ultimate allocation of liabilities to the individual partners of those feeder entities