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Internal Revenue Service Target Company

The United States Internal Revenue Service is a bureau of the United States Department of the Treasury. The IRS is charged with collecting revenue and enforcing the Internal Revenue Code.  
Holland & Knight LLP

Independent Sponsors: Section 1202 Qualified Small Business Stock

Holland & Knight LLP on

The tax benefits conveyed by Section 1202 of the Internal Revenue Code to owners of qualified small business stock (QSBS) have been available to small business owners in some form since Section 1202 was first enacted in 1993....more

Rivkin Radler LLP

The Transaction That Failed – Tax Treatment of Termination Fees

Rivkin Radler LLP on

Deal Costs, Generally- Every purchase and sale of a business, whether from the perspective of the seller or the buyer, is about economics, and few items will impact the economics of the transaction more certainly or...more

Rivkin Radler LLP

Gifting Business Interests Before Selling the Business? Think Valuation

Rivkin Radler LLP on

Counting the Days?- We are 302 days away from the national mid-term elections, to be held November 8, 2022, yet the first full week of the new year has already highlighted some of the economic issues with which the...more

Rivkin Radler LLP

Selling Your S Corporation’s Business? What If It’s Not an S Corporation?

Rivkin Radler LLP on

Haste Makes Waste? How many of you are suffering from Build Back Better Fatigue? Seriously, it’s a thing. Sure, the House passed its version of the President’s tax and spending bill on November 19, and the Senate...more

Dorsey & Whitney LLP

Canadian Corporations Acquiring U.S. Target Companies in Tax-Deferred Transactions: When Business Activities Outside the U.S....

Dorsey & Whitney LLP on

In transactions in which a Canadian corporation seeks to acquire a U.S. target entity for shares of the Canadian acquiror in a transaction intended to be tax-deferred for U.S. federal income tax purposes, the ability of U.S....more

Skadden, Arps, Slate, Meagher & Flom LLP

IRS Determined a Subsidiary Stock Sale Does Not Make Prior Capitalized Transaction Costs Deductible

A recent Technical Advice Memorandum (TAM) issued by the Internal Revenue Service (IRS) National Office concludes that a target company required under Internal Revenue Code Section 263(a) regulations to capitalize costs that...more

Farrell Fritz, P.C.

Taxpayers Bear The Tax Consequences Of Business Decisions

Farrell Fritz, P.C. on

It is a basic precept of the tax law that the substance of a transaction, rather than its form, should determine its tax consequences when the form of the transaction does not coincide with its economic reality. This...more

Proskauer - Tax Talks

IRS and Treasury Issue More Guidance on “Inversion” Transactions

Proskauer - Tax Talks on

The Treasury Department and the Internal Revenue Service have issued additional guidance about so-called “inversion” transactions. Generally, an inversion transaction results where a U.S. corporation (“U.S. Target”) is...more

Latham & Watkins LLP

Four Trends in Master Limited Partnership M&A in 2014

Latham & Watkins LLP on

MLP merger and acquisition activity can take a number of different forms to unlock value for sponsors and unitholders. Background - In the first half of 2014, master limited partnership (MLP) mergers and...more

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