This Month in M&A

January 2014

This month features:

  • IRS issues ruling excluding deferred intercompany gain from gross income under discretionary rule (PLR 201352007)
  • Eleventh Circuit interprets tax sharing agreement between members of consolidated group to determine ownership of tax refund (In re Netbank, Inc., 729 F.3d 1344)
  • Proposed regulations to foreclose attempts to accelerate deductions for unamortized organizational expenses and start-up expenditures (REG-126285-12)
  • Proposed regulations provide guidance on determining partner’s share of recourse liabilities in certain contexts (REG-136984-12)
  • Revenue Procedure provides safe harbor for partnership allocations of Section 47 rehabilitation credits (Rev. Proc. 2014-12)
  • Exchange of pre-existing Distributing debt for Controlled stock in monetized spin-off transaction qualifies as tax-free (PLR 201349006)
  • Segregation rules apply to loss corporation in pro rata spin-off, causing creation of new public group (PLR 201350006)

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

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

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