Andrew Mitchel LLC

International Tax Blog - New and Interesting International Tax Issues


Chart of PLR 201328003 - Deemed Distribution and Contribution with Circular Flow of Cash

2013-09-25

Below is a chart of PLR 201328003 in which the IRS held that a circular flow of cash was disregarded and a deemed distribution and contribution occured. 

The chart can be viewed as a PDF file here: PLR 201328003

PLR201328003

Tags: 368 Corporate Reorgs, Charts - Situational Charts, Other - Circular flow of cash