This Month in M&A - July 2012

July 2012

This Month's Features:

  • New section 7874 regulations make corporate “inversions” more difficult for many multinationals
  • Tax Court upholds taxpayer’s debt characterization of US intercompany debt (NA General Partnership v. Commissioner)
  • Final regulations modify election for consolidated group to avoid immediately taking into account deferred gain recognized upon liquidation of another member
  • IRS will not challenge publicly traded partnership’s conclusion that certain cancellation of debt income is “qualifying income” (Rev. Proc. 2012-28)

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Tim Lohnes
Partner, M&A Tax
Tel: +1 (202) 414 1686

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