IRS Says Taxpayers Can Continue to Rely on Expiring Rules on Continuity of Interest

The Internal Revenue Service March 18 said taxpayers can continue to rely on proposed and temporary rules (REG-146247-06, T.D. 9316) on the continuity of business interest requirement in…

IRS Focused on Global Issues, Greater Cooperation, Transparency, Former Deputy Commissioner Says

Taxpayers can expect a sharp focus on global issues at the Internal Revenue Service going forward, marked by closer relationships with other taxing authorities, an…

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

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…

IRS Says Transfers Within Foreign Parent Corporation’s U.S. Life Groups Will Qualify as Exchanges Under Section 351

The Internal Revenue Service in Private Letter Ruling 201006002, released Feb. 18, said transactions contemplated in connection with a foreign parent corporation’s eventual merger of its two U.S. life insurance groups will qualify as…

ANALYSIS: ‘Isolated’ Redemptions Do Not Trigger Constructive Distributions

Robert Willens, president of tax and consulting firm Robert Willens LLC in New York, examines recently issued…

ANALYSIS: Deducting ‘Going Private’ Expenses

In November of Year 1, the board of directors of “Company” (C) decided to “explore strategic alternatives,” including a sale of C.

An “exclusivity agreement” (with “Sponsors”) was…

IRS Rules Conversion of Foreign Subsidiary, Transfer of Assets Will Be ‘F’ Reorganization

The Internal Revenue Service ruled in Private Letter Ruling 201001002, released Jan. 8, that a corporate reorganization transaction proposed by the parent of a consolidated return group involving the conversion of a foreign subsidiary to a new entity and transfer of its assets to a new corporation will qualify as…

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