This Month's Features:
- Section 355 monetization transaction subject to section 367(a) ruled not a "device" (PLR 201232014)
- Equity investor held not a bona fide partner in partnership (Historic Boardwalk Hall, LLC v. Comm'r)
- Preferred stock found to be non-qualified preferred stock, thereby denying intended capital loss planning (Gerdau MacSteel v. Comm'r)
- Transferor met the section 351(a) control requirement notwithstanding the transferee corporation's shares were directly issued to unrelated persons (PLR 201232030)
- PwC highlights issues in guidance on outbound asset reorganizations (PwC comment letter to Notice 2012-39)
