June 21, 2021 2021-1236 Tax M&A Update for May 2021 Tax M&A Update is a monthly newsletter that provides a summary of developments in the marketplace, leading technical developments, and other thought leadership notes in the area of mergers and acquisitions (M&A) taxation and general corporate taxation. Highlights of this edition include: - Sell the distributor: Section 336(e) and becoming unrelated;
- General NOL waiver cuts off ability to carry back specified liability losses; and
- Dividend from closely-held corporation subject to net investment income tax
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