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ANALYSIS: Separate Return Limitation Year Rules, ‘Hook Stock’ Among Items Addressed in Recent IRS Corporate Private Letter Rulings of Note

March 4, 2010 in Daily Tax Report · Leave a Comment 

Jasper L. Cummings, Jr. of Alston & Bird LLP examines recent private letter rulings of note involving corporate taxpayers. He examines PLR 201003012′s demonstration of how to combine two related corporations into a new consolidated group and soften the impact of the separate return limitation year rules of Regulations Section 1.1502-21(c), and says PLR 201007045 shows a different way for a consolidated group to eliminate “hook stock” by in effect selling it outside…

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