No taxable event for change of corporate form

Notwithstanding any provision of the Internal Revenue Code of 1986, a change in the organizational structure of a corporation, however organized, into another organizational structure is not a taxable event for the purposes of such Code if there is no change among the owners, their ownership interests, or the assets of the organization (other than a de minimis change in such assets). The preceding sentence shall apply to changes in organizational structure occurring after December 31, 2024.