News & Analysis as of

Complex Corporate Transactions Internal Revenue Service

Holland & Knight LLP

Tax Planning Prevails in Parkway Gravel Decision

Holland & Knight LLP on

The U.S. Tax Court recently issued an opinion in Parkway Gravel Inc. v. Commissioner, Docket No. 10819-21, respecting the structure of a gravel company's sale of a land parcel known as the Freeway Pit. In finding for the...more

Foley & Lardner LLP

Acquiring a New 401(k) Plan in an M&A Transaction… Now What?

Foley & Lardner LLP on

401(k) Plan Mergers and Updated IRS Determination Letters - As part of an M&A transaction, your company may assume a new 401(k) plan that is sponsored by the acquired business. This article includes some common questions...more

BCLP

IRS Expands Determination Letter Program for Mergers of Qualified Plans Following Corporate Transactions

BCLP on

The IRS recently reversed course on the availability of the determination letter program for merged qualified retirement plans – thereby providing new alternatives for integrating qualified retirement plan benefits in the...more

Eversheds Sutherland (US) LLP

Think twice before deducting success-based fees - new Chief Counsel Advice denies deduction of success-based fee due to lack of...

On June 21, 2018, the Internal Revenue Service (IRS) issued Chief Counsel Advice (CCA) 2018-30-011, which disallowed a taxpayer’s deduction of a portion of a success-based fee incurred in a corporate transaction because the...more

Eversheds Sutherland (US) LLP

IRS announces campaign to review corporate transaction costs

New Campaigns Announced - On March 13, 2018, the Large Business and International (LB&I) Division of the Internal Revenue Service (IRS) announced five new compliance campaigns. The five campaigns supplement the 13 initial...more

Eversheds Sutherland (US) LLP

Think Twice: Costs Associated with Regulatory Approval for Corporate Transactions May Be Deductible

Although the cost of obtaining regulatory approval for a corporate transaction is identified as facilitative, a recent Chief Counsel Advice (CCA 2017-13-010, March 31, 2017) (the CCA) issued by the Internal Revenue Service...more

McGuireWoods LLP

Tax Policy Update

McGuireWoods LLP on

As in the 9 percent "amusement tax" that the city of Chicago recently extended to online streaming services like Netflix and Amazon Prime, triggering a series of lawsuits alleging that the newly expanded tax was illegally...more

Baker Donelson

Practice Spotlight: Corporate Inversions and Related Transactions

Baker Donelson on

The past several months have seen a flurry of business activity by and between U.S.-based corporations and foreign competitors. Mergers have been announced between foreign and domestic pharmaceutical companies, drug retailers...more

8 Results
 / 
View per page
Page: of 1

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
- hide
- hide