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This session will cover a range of current issues and trends concerning the federal income taxation of merger and acquisition transactions, including: withholding issues in a deal context; expanded use on rep/warranty insurance in deals; I.R.S. P.L.R. 202146003 and the actual knowledge rule under section 382; the application of section 382 to controlled foreign corporations under section 382(e)(3); loss monetization in anticipation of potential Granite Trust repeal; and M&A issues with accrual-basis taxpayers acquiring cash-basis taxpayers.
