This Month's Features:
- Proposed regulations provide guidance on the net investment income tax under section 1411 (REG-130507-11)
- Section 1504 affiliation permitted for parent's direct subsidiary with more than 20 percent of its stock owned through hook stock (PLR 201240017)
- Shareholder loan to Distributing respected as bona fide debt where Distributing subsequently used borrowed funds to equalize value in controlled entities prior to section 355 spin-off (PLR 201240013)
- IRS illustrates factors in determining tax ownership of subsidiary stock with respect to affiliation requirements of section 1504(a) (AM 2012-007)
- 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)
