This Month's Features:
- New section 7874 regulations make corporate “inversions” more difficult for many multinationals
- Tax Court upholds taxpayer’s debt characterization of US intercompany debt (NA General Partnership v. Commissioner)
- Final regulations modify election for consolidated group to avoid immediately taking into account deferred gain recognized upon liquidation of another member
- IRS will not challenge publicly traded partnership’s conclusion that certain cancellation of debt income is “qualifying income” (Rev. Proc. 2012-28)
