The 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

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

Seth J. Entin (Contact Author)

Greenberg Traurig ( email )

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Miami, FL 33131
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305-579-0615 (Phone)

HOME PAGE: http://https://www.gtlaw.com/en/professionals/e/entin-seth-j

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