2026-01-05
The IRS recently published PLR 202551006. This PLR grants late election relief under Code §362(e)(2)(C) for an outbound 351 exchange of built-in loss property. Without the election, the basis of the transferred property is stepped down to fair market value. With the election, the basis of the shares received in the foreign corporation is stepped down to fair market value. We created a chart of the PLR.
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