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LocalCo Merges into HeirCo, a Non-U

question 122

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LocalCo merges into HeirCo, a non-U.S. entity, in a transaction that would qualify as a "Type A" reorganization.
The resulting realized gain is tax-deferred under U.S. income tax law using §§ 351 and 368.


Definitions:

Economic Profit

Revenue minus the opportunity cost of resources used; usually less than the accounting profit.

Accounting Profit

Revenue minus explicit cost.

Factors of Production

The resources used in the creation of goods and services, traditionally categorized into land, labor, capital, and entrepreneurship.

Opportunity Cost

The real cost of an item: what you must give up in order to get it.

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