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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:

Colostomy

A surgical procedure that involves creating an opening in the abdominal wall for the colon, allowing diversion of fecal matter.

Sexual Activity

Behaviors involving the genital organs that aim to derive sexual pleasure or reproduction.

Body Image

An individual's perception of their physical self and the thoughts and feelings, positive, negative, or both, which result from that perception.

Sexually Transmitted Infections

Infections that are primarily spread through sexual contact.

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