September 2013

This Month's Features:

  • Final section 362(e)(2) regulations clarify limitations on duplication of net built-in losses (T.D. 9633)
  • Eighth Circuit affirms district court decision that lease restructuring transaction lacked economic substance (WFC Holdings Corp. v. United States)
  • IRS issues “single issue” section 355 ruling in just eight weeks (PLR 201333003)
  • Certain distributing shareholders receive section 305(a) treatment following a pro-rata spin-off (PLR 201333007)
  • Related-party stock sale of subsidiary followed by its taxable liquidation results in deferral of loss on the sale of stock under section 267(f) (PLR 201334006)
  • Subsidiary’s transfers of funds to foreign parent not treated as deductible interest under section 267(a)(3) (CCA 201334037)

This Month in M&A archive

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Mark Boyer
Global M&A Tax Leader – WNTS Mergers & Acquisitions Tax
Tel: +1 (202) 414 1629

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

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