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Technical Update: IRS PLR 202611002 and Downstream Mergers under Section 368(a)(1)(A)
This update summarizes IRS PLR 202611002, which confirms that certain downstream mergers can qualify as tax‑free reorganizations under Section 368(a)(1)(A) while meeting key requirements like continuity of interest and business enterprise. It also highlights the IRS’s favorable treatment of pre‑merger distributions as separate from merger consideration—offering planning opportunities to reduce shareholder tax exposure.
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