July 2013

This Month in M&A

This Month's Features:

  • IRS will restrict scope of letter rulings available under sections 332, 351, 355, 368 and 1036 (Rev. Proc. 2013-32)
  • Deferred loss recognized following formation of joint venture (PLR 201323005)
  • IRS analyzes licensing fees in determining worthless stock loss deduction under section 165(g) (PLR 201325007)
  • Tax Court partially denies installment sale treatment on sale of interest in partnership holding accounts receivable (Mingo v. Commissioner)
  • Supreme Court declines to review Third Circuit's decision in Historic Boardwalk Hall, LLC v. Commissioner
  • IRS applies section 752 anti-abuse rules to indemnity agreement in leveraged partnership transaction (CCA 201324013)
  • IRS addresses contribution of promissory note to disregarded entity (CCA 201326014)
  • IRS characterizes collaboration agreement as partnership (CCA 201323015)


This Month in M&A archive