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Alan Fischl, Tax Partner in the Washington office of PriceWaterhouseCoopers, covered a number of international tax matters, including dual consolidated losses, stapled stock, worthless stock deductions and the S.
367(b)-2(g) provides that the deemed conversion of a foreign corporation to a domestic corporation under the stapled stock rules of section 269B is considered an F reorganization for purposes of the section 367(b) regulations.