November 2013

This Month in M&A

This Month's Features:

  • Final regulations under Section 382 address exceptions to application of the segregation rules for certain transfers of loss corporation stock (T.D. 9638)
  • Taxpayer receives favorable ruling regarding nature of payments received in recent First Circuit District Court STARS decision (Santander)
  • In a Chief Counsel Advice, the IRS respects the characterization of an F reorganization followed by a leveraged triangular reorganization (CCA 201340016)
  • In a legal memorandum, the IRS concludes that a redemption of foreign corporation stock requires a corresponding reduction of foreign income taxes (AM 2013-006)


This Month in M&A archive