On 15 September 2023, the IRS released private letter ruling 202337007 (PLR). The PLR provides that a conversion of an entity disregarded for federal income tax purposes into a domestic corporation does not, by itself, give rise to a deemed exchange of debt.
Author
Daniel Stern
BrowsingDaniel V. Stern is a partner in the Firm's North America Tax Practice Group in Washington, DC. He mainly advises multinational and individual clients on corporate tax planning and tax dispute resolution matters. Mr. Stern has written numerous articles on domestic and international tax topics, and is a frequent speaker at Bloomberg BNA, TEI and Baker McKenzie client seminars. His pro bono work includes representing low-income taxpayers, assisting Nepal in drafting a new constitution and advising the International Summit on the Legal Needs of Street Youth.