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This Month in Mergers and Acquisitions for May 2021

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May 2021

This month's features:

  • PLR concludes that an accelerated stock repurchase program does not result in a device for the distribution of earnings and profits
  • PLR addresses spin-off consequences regarding ‘hot stock’ and use of boot consideration to satisfy internal creditors
  • TAM addresses assumption of liabilities in a deemed liquidation of an insolvent corporation
  • DC Circuit reviews Tax Court decision respecting an investor as bona fide partner


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Julie Allen

National Tax Services Market Leader and Mergers and Acquisitions Tax Leader, PwC US

Tim Lohnes

Partner, M&A Tax, PwC US

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