This Months in M&A - April 2012

April 2012

This Month's Features:

  • IRS applies "Discretionary Rule" to exclude intercompany gain resulting from downstream merger (PLR 201210018)
  • Open market stock repurchases by a distributing corporation may not count for purposes of Section 355(e) (PLR 201211008)
  • Section 355 treatment granted despite liquidation of distributed corporation (PLR 201213018)
  • Consistency rules of Section 338(e) do not apply to partnership's purchase of assets from a target corporation (PLR 201213013)
  • Stock sale disregarded under rescission doctrine (PLR 201211009)
  • Taxpayer's contribution of chain of wholly owned subsidiaries to another corporation followed by deemed liquidations did not result in gain or loss recognition; IRS did not characterize transactions (PLR 201212001)
  • IRS grants relief to life insurance company to join in the filing of a life-nonlife consolidated return (PLR 201210015)
  • IRS waives five-year restriction on reconsolidation following deconsolidation (PLR 201213012)

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Tim Lohnes
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