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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.
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Strategies or elements designed to assist readers in understanding or navigating through text more easily.
Negative Message
Communication that conveys bad news, rejection, or feedback that might not be favorable to the recipient.
False Hopes
Unfounded or unrealistic expectations that are unlikely to come to fruition.
Positive Language
The use of words and phrases that promote a constructive or optimistic outlook, often employed to encourage, motivate, or influence others positively.
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