May 2013

This Month in M&A

This Month's Features:

  • No liquidation-reincorporation where reincorporated assets spun-off as part of overall plan (PLR 201315016)
  • Obama Administration FY2014 budget focuses on tax reform, business tax proposals, and new tax initiatives
  • Insolvent corporate partner includes distributive share of partnership’s gross receipts for section 165(g)(3)(B) purposes (PLR 201314005)
  • Tax Court holds that funds received through a controlled foreign corporation were in substance dividend payments (Barnes Group)


This Month in M&A archive