This Month's Features:
- Proposed regulations provide initial guidance on corporate equity reduction transactions (CERTs)
- Tax Court treats related-party advance agreements as equity rather than debt (PepsiCo, Inc. v. Comm’r)
- US District Court concludes entities were sham partnerships even if transactions had economic substance (Broadwood Investment Fund LLC v. United States)
- Supplemental ruling respects back-to-back F reorganizations that occurred pursuant to an overall plan (PLR 201239003)
- CCA treats preferred stock as common stock for purposes of section 302(b)(2) (CCA 201236025)
