In This Issue:

- Congress Passes Year-End Tax Extenders Bill

- House Adopts New “Dynamic Scoring” Rule

- Foreign Fund Engaged in Lending and Stock Distribution Not Protected by “Trading in Stock or Securities” Safe Harbor

- IRS Addresses Distribution by Corporation Electing to be Treated as REIT

- REIT Preferential Dividend

- Reporting Requirement for Payments to LLCs

- IRS Recharacterizes Offsetting Contracts

- IRS Applies Section 956 Anti-Abuse Rule (Again) to Recharacterize Backto- Back Loans

- IRS Revisits Prior Letter Rulings; Disapproves of “Costless Collar” Transaction

- PLI Webinar: Moving Away From The C-Corporation: Understanding REITs, MLPs, and PTPs

- MoFo in the News; Awards

- Excerpt from Congress Passes Year-End Tax Extenders Bill:

On December 19, just days before the end of 2014, President Obama signed into law the Tax Increase Prevention Act of 2014 (TIPA). TIPA retroactively extended a number of tax breaks for 2014 that had expired at the end of 2013. While we won’t bore our readers by reciting chapter and verse, there are a few key provisions of the tax extender’s bill worth mentioning. Specifically, taxpayers will still enjoy the benefit of the following tax breaks for 2014...