This Month in MA December 2020

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December 2020


This month's features:

  • Cash contributions in a “north-south” transaction do not affect spin-off distribution from qualifying as tax-free (PLR 202045003)
  • Liberty Global Inc. v. United States and the validity of the Section 245A regulations
  • IRS releases PLR addressing the impact of Section 958(b)(4) repeal in an outbound transfer of domestic corporation stock (PLR 202045007)
  • IRS disregards ‘circular’ transfers of notes and cash executed under a binding commitment (PLR 202048003)
  • IRS rules that Section 721(c) property is no longer subject to Gain Deferral Method following partnership’s deemed transfer to a foreign corporation (PLR 202047006)
  • Treasury and the IRS issue 2020-2021 Priority Guidance Plan
  • Guidance issued for partnerships, S corporations on SALT deduction limit (Notice 2020-75)

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Tim Lohnes

Partner, M&A Tax, PwC US

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