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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

Letter Ruling Addresses C Corporation’s Conversion to a REIT

February 3, 2015 By Jasper L. (Jack) Cummings, Jr.

The IRS recently released the letter ruling (PLR 201503010) that was likely issued to Iron Mountain, a US multinational document storage company, on its conversion to a REIT. The taxpayer in the ruling proposed retaining its leases and ownership interests in warehouse-like buildings and racking structures therein in the corporation that would elect REIT status and moving its document storage activities into taxable REIT subsidiaries. The letter ruling contained more than a dozen separate rulings, evincing the complexity of transitioning from a C corporation to a REIT, particularly when [...]Read more

Filed Under: Corporate - Federal, Federal Tax Advisory, RICs, REITs and other Special Entities Tagged With: change of accounting method, conversion to REIT, E&P, IRS letter ruling, proposed regulations, real property, REIT, REIT subsidiary, section 481, section 856

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