M&A tax recent guidance (April 2014) featuring principles of Commissioner’s Discretionary Rule applied for taxpayer favorable result

This Month in M&A

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.


This Month in M&A archive