This Month's Features:
- IRS applies "Discretionary Rule" to exclude intercompany gain resulting from downstream merger (PLR 201210018)
- Open market stock repurchases by a distributing corporation may not count for purposes of Section 355(e) (PLR 201211008)
- Section 355 treatment granted despite liquidation of distributed corporation (PLR 201213018)
- Consistency rules of Section 338(e) do not apply to partnership's purchase of assets from a target corporation (PLR 201213013)
- Stock sale disregarded under rescission doctrine (PLR 201211009)
- Taxpayer's contribution of chain of wholly owned subsidiaries to another corporation followed by deemed liquidations did not result in gain or loss recognition; IRS did not characterize transactions (PLR 201212001)
- IRS grants relief to life insurance company to join in the filing of a life-nonlife consolidated return (PLR 201210015)
- IRS waives five-year restriction on reconsolidation following deconsolidation (PLR 201213012)
