14 August 2025

Tax M&A Update for July 2025

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:

— The Section 338 approach to RBIG determinations remains viable
— Downward attribution prohibition (partially) restored
— Legislation supersedes 2004 technical advice memorandum

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Attachment

Tax M&A Update

Document ID: 2025-1688