On January 2, 2024, the Internal Revenue Service (IRS) released two revenue procedures updating the IRS guidelines for private letter ruling (PLR) requests, Revenue Procedure 2024-1 and Revenue Procedure 2024-3 (the 2024...more
Takeaways -
Tax law changes in the Build Back Better Act (BBBA) would limit the amount of value a company could extract in a spin-off by using a debt-for-debt exchange.
Companies may be able to achieve most of the...more
On September 9, 2019, the Treasury Department (Treasury) and the Internal Revenue Service (IRS) proposed regulations (proposed regulations) addressing items of income and deduction that are included in the calculation of...more
9/30/2019
/ Acquisitions ,
Built-In Gains ,
Change in Ownership ,
Corporate Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Loss Limitation Rules ,
Mergers ,
Net Operating Losses ,
Proposed Regulation ,
Section 382 ,
Tax Deductions ,
Tax Planning ,
U.S. Treasury
On June 7, 2016, the Internal Revenue Service (IRS) and Treasury Department issued new temporary regulations that have dramatic implications for all merger-and-acquisition activity by C corporations and real estate investment...more
6/9/2016
/ Acquisitions ,
C-Corporation ,
Capital Gains ,
Corporate Taxes ,
IRS ,
Mergers ,
Protecting Americans from Tax Hikes (PATH) Act ,
REIT ,
RICs ,
S-Corporation ,
Tax-Free Spin-Offs