October 2011

This Month in M&A

This Month's Features:

  • Benefits of structuring an IPO as an "Up-C"
  • Application of common-law economic substance doctrine in recent cases involving loss allocations
  • Cash distribution taxed under section 311 rather than 361(b) (PLR 201136009)
  • Taxpayer permitted losses following application of section 267(a)(1) and Treas. Reg. sec. 1.267(b)-1(b) (PLR 201138015)
  • Highlights of Obama Administration's recently released carried interest proposal
  • Selected corporate and partnership items in IRS 2011-2012 Priority Guidance Plan

This Month in M&A archive