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Mergers and Acquisitions

Second Inversion Notice

November 22, 2015 By Jasper L. (Jack) Cummings, Jr.

The Treasury issued the new Notice 2015-79 to beef up the anti-inversion section 7874. It contains three rules applicable to deals closing after the Notice and two rules that are retroactive to the 2014 Notice’s effective date. Those two rules increase the potential taxability of post-inversion restructurings. The three prospective rules are the most surprising and potentially harmful to taxpayers seeking to invert. They all relate to the use of holding company structures, which are common in cross border tax planning. Holding company structure rules: If the foreign acquiring corporation [...]Read more

Filed Under: Federal - Corporate Tax Planning, International - Corporate Tax Planning, Mergers and Acquisitions Tagged With: Notice 2015-79

REIT Real Property Regulation Proposed

May 20, 2014 By Jasper L. (Jack) Cummings, Jr.

Prop. Reg. section 1.856-10 will define real property that will satisfy the income and asset requirements for REITs. It will replace Reg. section 1.856-3(d). It claims to be a clarification of existing law and not a modification that would cause significant reclassifications for existing REITs, and that seems to be true. It embodies the positions stated in the much briefer current regulation, plus several revenue rulings and letter rulings issued over the years. The regulation aims to rationalize the process of identifying real property so that REITs can decide for themselves whether they own [...]Read more

Filed Under: Mergers and Acquisitions, RICs, REITs and other Special Entities Tagged With: Domestic

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