This Month's Features:
- Final "Hot Stock" regulations
- Proposed regulations for redetermining consolidated NUBIG/NUBIL
- Proposed regulations removing the de minimis partner rule
- District Court rules lease restructuring transaction lacked economic substance
- District Court rules foreign tax credit generating transaction lacked economic substance
- IRS respects rescission of intercompany stock sales (PLR 201140008)
- Taxpayer deemed to satisfy active trade or business requirement for exception to section 367(a)(1) (PLRs 201141011 and 201141012)
