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Killing the Killer B: The Treasury and IRS Issue a Sixth Set of Rules on Killer B Transactions

December 15, 2016 By Jasper L. (Jack) Cummings, Jr. and Stefanie Kavanagh

The Treasury looks to slay Killer B transactions with its newest rules. Our International Tax Group follows the trail of glitches in the regulation.

Read the full advisory here.

Filed Under: International Tax Advisory Tagged With: Acquiring A, Advisory, CFC, E&P, Earnings and Profits, foreign corporation, international tax, IRS, Issuer A, Killer B, Notice 2014-32, Notice 2016-73, REg 1.367(b)-10, Section 301, Section 367, Section 956, stock-for-stock B, Treasury

About Jasper L. (Jack) Cummings, Jr.

Jack Cummings is counsel in the Federal Tax Group of Alston & Bird in Raleigh and Washington, D.C. He served as IRS associate chief counsel (corporate) and chair of the Corporate Tax Committee of the ABA Section of Taxation.

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About Stefanie Kavanagh

Stefanie Kavanagh is an associate in the Federal & International Tax Group. She focuses her practice on tax planning and structuring for domestic and international business entities as well as matters relating to real estate investment trusts.

[Read Bio]

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