Federal Tax Advisory – GLAM 2012-007
This advisory discusses a general legal advice memorandum (GLAM) in which the IRS Chief Counsel advises the field that a subsidiary does not enter a corporate group when the common parent buys the stock needed for affiliation for a note carrying below-market interest so as to compel the seller to exercise its right to take the stock back after two years.
The advisory is provided in PDF on the Alston & Bird website: www.alston.com/advisories/federal-tax-advisory-december-2012
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