Despite recent Internal Revenue Service (IRS) guidance on tax issues, mergers and acquisitions attorneys still face unanswered questions. While the IRS has addressed many topics in mergers and acquisitions - such as proposed rules to eliminate safe harbor methods for built-in gains and losses when a corporation experiences ownership changes and finalizing 2016 temporary regulations that imposed corporate-level tax on real estate investment trust transactions that had been perceived as overly burdensome - other areas remain unclear.
When asked to provide additional guidance regarding the treatment of contributions to partnerships, Attorney Mark Melton said, "there are two similar transactions that involve a buyer purchasing an interest in an LLC, but the ordering can trigger dissimilar tax results in how the partnership distributions are treated."
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