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