This Month in Mergers and Acquisitions for June 2020

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June 2020

This month’s features:

  • IRS releases GLAM concluding that a meaningless gesture contribution results in a split basis and holding period in a corporation’s stock (AM 2020-005)
  • Treasury and the IRS finalize regulations under Section 385 (TD 9897)
  • Revenue Procedure 2020-19 provides temporary liquidity relief for publicly offered REITs and RICs
  • Revenue Procedure 2020-30 provides temporary relief pertaining to foreign branch dual consolidated loss issues and related Form 8858 filing issues
  • IRS addresses interaction of NOL carrybacks and corporate AMT
  • Tenth Circuit applies state law to determine distribution of tax refund within consolidated group (Rodriguez v. Federal Deposit Insurance Corp., No. 17-1281 (10th Cir. 2020))

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David Hall

Mergers & Acquisitions (M&A) Tax Leader, PwC US

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