Surprisingly, in the midst of the COVID-19 emergency, final regulations under Section 901(m) were published. While important for M&A transactions, Section 901(m) had largely been treated as an afterthought in light of the...more
On March 19, 2019, the Internal Revenue Service (IRS) and Treasury Department (Treasury) issued final regulations (T.D. 9851) (Final Regulations) under section 851 addressing the income test applicable to regulated investment...more
3/25/2019
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