Our April edition features recent M&A tax guidance, including:
- Principles of Commissioner’s Discretionary Rule applied for taxpayer favorable result on noncapital, nondedectible intercompany loss (PLR 201411007)
- Trust holding rental real estate property held to qualify for Section 469(c)(7) passive activity exception (Frank Aragona Trust)
- Section 355 ruling permits distributed corporation to elect classification as REIT after distribution (PLR 201411002)
- IRS pauses consideration of ruling requests on publicly traded partnerships satisfying qualifying income requirements.