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After TCJA: A U.S. citizen, owns 1% of USAco, a domestic corporation. All other shareholders of USAco are unrelated foreign persons. In a Type B
After TCJA: A U.S. citizen, owns 1% of USAco, a domestic corporation. All other shareholders of USAco are unrelated foreign persons. In a Type B reorganization, FORco transfers shares of its voti...
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