This Month in M&A

May 2014

This month features:

  • IRS to issue Section 367 regulations on property used to acquire parent stock or securities in triangular reorganizations involving foreign corporations, effective April 25, 2014 (Notice 2014-32)
  • IRS concludes that the vote and value of a target company’s shares remained with the seller until the purchaser actually bought the shares and they were released by the escrow agent to the purchaser (CCA 201414015)
  • IRS examines Section 465 consequences when a member of a limited liability company classified as a partnership or disregarded entity for federal tax purposes guarantees debt of the LLC (GLAM 2014-003)

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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