30 July 2024 Internal T.I. 2024-1019041I7 - Conversion from a XXXXXXXXXX -- summary under Corporation

A Delaware corporation was converted into an Iowa limited liability company pursuant to provisions in the applicable statutes that contemplated that the converted entity was the same entity as the converted corporation. The Directorate indicated that since both companies were corporations for ITA purposes, it would rely on the foreign company law, which treated the conversion as not entailing the converted company as ceasing to exist and to instead be continued, so that it would treat the Iowa LLC as the same entity as the Delaware corporation.