This Month in M&A - October 2012

October 2012

This Month's Features:

  • Proposed regulations provide initial guidance on corporate equity reduction transactions (CERTs)
  • Tax Court treats related-party advance agreements as equity rather than debt (PepsiCo, Inc. v. Comm’r)
  • US District Court concludes entities were sham partnerships even if transactions had economic substance (Broadwood Investment Fund LLC v. United States)
  • Supplemental ruling respects back-to-back F reorganizations that occurred pursuant to an overall plan (PLR 201239003)
  • CCA treats preferred stock as common stock for purposes of section 302(b)(2) (CCA 201236025)

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

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