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This document is a private letter ruling from the Internal Revenue Service regarding the exchange of shares for U.S. persons and the qualifications for an exception to the general rule under § 367(a)
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Who needs PLR-116457-11?
01
Individuals or entities seeking a specific determination or ruling relevant to their situation under IRS guidelines.
02
Taxpayers needing clarification on tax-related matters affecting their financial affairs.
03
Businesses looking to ensure compliance with tax regulations and seeking to resolve potential issues.
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What is PLR-116457-11?
PLR-116457-11 is a Private Letter Ruling issued by the Internal Revenue Service (IRS) relating to specific tax issues or questions presented by taxpayers.
Who is required to file PLR-116457-11?
Taxpayers who seek a ruling on specific tax-related questions or issues are required to file PLR-116457-11.
How to fill out PLR-116457-11?
To fill out PLR-116457-11, taxpayers need to complete the required forms and provide detailed information regarding their specific tax issues, along with the applicable fee.
What is the purpose of PLR-116457-11?
The purpose of PLR-116457-11 is to provide taxpayers with written confirmation of the IRS's interpretation of tax laws as they apply to the taxpayer's specific situation.
What information must be reported on PLR-116457-11?
PLR-116457-11 must include information such as the taxpayer's identification details, the specific tax issue being addressed, relevant facts, and any legal arguments supporting the taxpayer's position.
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