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February 16, 2022
2022-0278

Tax M&A Update for January 2022

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:

— IRS invokes Section 956 anti-abuse rule for group lending arrangement;

— Looking through domestic partnerships for Subpart F purposes; and

— Accelerated process for spin-off PLRs.

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Tax M&A Update