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. ——————————————— ATTACHMENT Tax M&A Update
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