This Month in M&A includes articles on tax planning & current developments

This Month in M&A

This month features:

  • Proposed regulations would clarify definition of real property for REIT purposes (REG-150760-13)
  • Proposed anti-inversion legislation would significantly strengthen the threshold for applying section 7874 (Stop Corporate Inversions Act of 2014)
  • Proposed regulations would limit ability to choose tax attribute location following asset reorganizations (REG-131239-13)
  • Section 355 spin-off PLR applies section 355(e) where corporations are owned by partnerships (PLR 201422004)
  • IRS grants 9100 relief to make a late election under section 362(e)(2)(C) (PLR 201418034)
  • Loan from CFC to US parent corporation does not mitigate section 956 income inclusion to US parent (CCA 201420017)


This Month in M&A archive