This Month in Mergers and Acquisitions for February 2021

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February 2021

Overview

This month’s features:

  • Final Section 163(j) regulations provide additional guidance for deduction limitation on business interest expense (TD 9943)
  • Final Section 1061 regulations provide significant changes to rules addressing long-term capital gain treatment related to certain partnership interests (TD 9945)
  • Tax Court rules on characterization of funds provided by partners to a partnership (Hohl v. Commissioner)
  • IRS Revenue Procedure lists areas in which rulings and determination letters will not be issued (Rev. Proc. 2021-3)
  • IRS issues notice providing relief for partnerships related to the reporting of partners’ beginning capital account balances (Notice 2021-13)

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