This Month in Mergers and Acquisitions for January 2020

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January 2020

Overview

This month’s features:

  • Final regulations under Section 355(e) provide clarity on predecessors and successors
  • Partnership aspects of the proposed and final foreign tax credit regulations
  • Treasury issues proposed regulations under Section 162(m)
  • IRS issues Notice delaying implementation of new partnership reporting requirements
  • Internal IRS guidance memorandum illustrates scope of BBA audit rules and interaction between individual and partnership audits

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Tim Lohnes

Partner, M&A Tax, PwC US

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