October 2013

This Month's Features:

  • Much anticipated section 355 ruling permits taxpayer to spin off real estate assets into a REIT (PLR 201337007)
  • Tax Court denies consolidated return loss based on 1934 Supreme Court decision (Duquesne Light Holdings)
  • Taxpayer successfully uses the IRS’s arguments against it in recent Tax Court STARS decision (Bank of New York)
  • Proposed regulations under sections 334(b)(1)(B) and 362(e)(1) address importation of losses in nonrecognition transactions

This Month in M&A archive

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