July 2012

This Month in M&A

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)


This Month in M&A archive