Download This PaperThe No-Existence Theory and Pre-Immigration Check-the-Box Planning
Tax Notes Federal, Volume 166, Number 3 ■ January 20, 2020
11 Pages Posted: 2 Mar 2020
Date Written: January 20, 2020
Abstract
This article examines the “noexistence” theory and considers whether an entity that is not “relevant” is deemed to exist, focusing on liquidation and basis step-up under
sections 336 and 334.
Suggested Citation: Suggested Citation
Entin, Seth J., The No-Existence Theory and Pre-Immigration Check-the-Box Planning (January 20, 2020). Tax Notes Federal, Volume 166, Number 3 ■ January 20, 2020, Available at SSRN: https://ssrn.com/abstract=3529423
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