M&A tax recent guidance for March 2014

This Month in M&A

This Month in M&A features:

  • Key M&A proposals in President Obama's FY2015 budget and Chairman Camp's tax reform discussion draft
  • Conservation partnership's capital cash contribution to an LLC followed by the LLC's allocation of state tax credits to the partnership held to be a disguised sale under section 707(a) (Route 231 LLC v. Commissioner)
  • Public spinoff qualifies as tax-free spin-off and D reorganization; portion of Controlled stock retained to satisfy third-party indebtedness (PLR 201409002)
  • Intra-group spin-off and subsequent outbound spin-off of US corporation ruled tax-free even though no subsequent representations or rulings on foreign restructuring steps (PLR 201408010)
  • Liquidations of subsidiaries not treated as part of reorganization; assumption of shareholder liabilities treated as separate distribution taxable under section 301 (PLR 201406005)


This Month in M&A archive