November / December 2012

This Month in M&A

This Month's Features:

  • Proposed regulations provide guidance on the net investment income tax under section 1411 (REG-130507-11)
  • Section 1504 affiliation permitted for parent's direct subsidiary with more than 20 percent of its stock owned through hook stock (PLR 201240017)
  • Shareholder loan to Distributing respected as bona fide debt where Distributing subsequently used borrowed funds to equalize value in controlled entities prior to section 355 spin-off (PLR 201240013)
  • IRS illustrates factors in determining tax ownership of subsidiary stock with respect to affiliation requirements of section 1504(a) (AM 2012-007)

This Month in M&A archive