F Reorganizations & New EINs

Technical topics regarding tax preparation.
#1
Wiles  
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I have read several articles and am not getting any clear guidance. For example:
https://www.thetaxadviser.com/issues/20 ... ry-11.html
Use of Rev. Rul. 73-526 in “Drop and Check” Transaction
An F reorganization can involve the shareholders of an existing state law corporation (historic corporation) dropping the shares of that corporation into a newly formed state law corporation (Newco) and then converting the historic corporation to a single-member limited liability company that defaults to a disregarded entity for federal tax purposes. The IRS needs to clarify whether the historic EIN of the corporation that converts to an LLC is retained by that LLC, as the IRM allowed, or is reassigned to a new company, as allowed in a recent letter ruling.


Prior structure: Shareholder owns Oldco Inc. (S-Corp)
New structure: Shareholder own Newco Inc. (S-Corp) which owns Oldco LLC (DRE)

Who gets Oldco's EIN? And who applies for a new EIN?
 

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