This Month in MA (September 2020)

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September 2020


This month’s features:

  • Treasury issues final and proposed regulations under Section 245A (TD 9909) (REG-124737-19)
  • Treasury and the IRS release final regulations under Section 59A (the base erosion and anti-avoidance tax or BEAT) (TD 9910) 
  • Tax treatment of certain S corporations for subpart F income and GILTI purposes (Notice 2020-69)
  • IRS rules that a transaction qualifies as a reorganization under Section 368(a)(1)(F) despite midstream change in plan (PLR 202031002)

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Tim Lohnes

Partner, M&A Tax, PwC US

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