LocalCo merges into HeirCo, a non-U.S. entity, in a transaction that would qualify as a "Type A" reorganization. The resulting realized gain is tax-deferred under U.S. income tax law, using ยงยง 351 and 368
a. True
b. False
Indicate whether the statement is true or false
False
RATIONALE: Section 367 can trigger current taxation even in the case of an otherwise tax-deferred reorganization.
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