April 2013

This Month in M&A

This Month's Features:

  • Regulations under sections 367(a)(5) and 1248(f) address cross-border transfers
  • House Ways and Means Committee “discussion draft” would revamp subchapters K and S
  • “Commissioner’s Discretionary Rule” invoked to eliminate taxpayer’s deferred intercompany gains (PLR 201312027)
  • IRS reiterates its position that a sale of a partnership interest by a foreign partner constitutes effectively connected income (FAA 20123903F)


This Month in M&A archive