This Month in MA December 2020
December 2020
Overview
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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