This Month in Mergers and Acquisitions for March 2020

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March 2020

Overview

This month’s features: 

  • First “no-income” active trade or business ruling issued under Section 355 (PLR 202009002)
  • Supreme Court holds that federal common law does not govern distribution of tax refund within consolidated group (Rodriguez v. Federal Deposit Insurance Corp., 140 S. Ct. 713 (2020))
  • Taxpayer at-risk for amounts personally guaranteed (Bordelon v. Commissioner, T.C. Memo 2020-26 (2020))

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Tim Lohnes

Partner, M&A Tax, PwC US

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