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FIRPTA in the 21st Century — Installment Seven: A Valentine to Domestication

Weil Tax, Benefits, and Executive Compensation partner Kimberly Blanchard has authored the commentary “FIRPTA in the 21st Century — Installment Seven: A Valentine to Domestication,” discussing Notice 89-85 and the IRS’s recent private letter ruling, PLR 201321007, applying the Notice to a publicly traded foreign corporation that owned, as its sole asset, 100 percent of the stock of a US real property holding corporation (USRPHC) within the meaning of §897(c)(2) and domesticated by reincorporating as a US corporation.

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