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June 25, 2024

Tax M&A Update for May 2024

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:

— Tax Court rejects assignment of income, and other IRS arguments, in related party option agreement
— New spin-off PLR process and forthcoming regulations
— Commissioner’s discretion rule applied to nonstock asset

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Tax M&A Update