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Internal Revenue Service Number: 200533021 Release Date - IRS

Internal Revenue Service Number: 200533021 Release Date - IRS 2025

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The document is a private letter ruling from the Internal Revenue Service regarding the tax implications of a series of corporate transactions involving Old Parent and its subsidiaries. It outlines proposed asset transfers, stock exchanges, and mergers aimed at resolving disputes between two shareholder families (Family N and Family H) over the management of the businesses. The transactions are structured to qualify for tax-free treatment under various sections of the Internal Revenue Code, including sections 351 and 368. The document includes detailed descriptions of each step in the transaction process, along with closing agreements related to vessel transfers and capital construction funds.

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