Internal Revenue Code provisions governing the tax or tax-free treatment of corporate acquisitve reorganizations have morphed and mutated ad hoc over the past 80 years. The basic "A," "B," and "C" acquisitive reorganizations reflect early types of acquisitive transactions used in the business world. 

In his article in Taxes-The Tax Magazine, Richard M. Weber, Jr., provides an overview of the current rules governing acquisitive reorganizations and compares the complexity of the current acquisitive reorganization regime with the complexities of the former entity classification rules.

Like the classic Killer B transaction in which the CFC paid the parent for its stock, Kevin Rowe and Jack Cummings in their column in Corporate Business Taxation Monthly point out, this transaction is also apparently seen as a way for the CFC to repatriate foreign earnings without drawing U.S. corporate-level income tax.

An article in Property Tax Alert explains what to do as local jurisdictions' increasing needs for funds, coupled with enhanced technology, is leading to more cross-referencing of records and subsequent assessments.

Code Sec. 355 is exclusively a Subchapter C rule, so using Code Sec 355 and partnerships in the same breath may seem a bit odd. It is axiomatic that the active conduct of a trade or business does not include holding property for investment. But what of corporations that hold partnership or LLC interests? 

An article by Robert Wood in M&A Tax Report details IRS guidance on the subject. 

Yet, according to an article in Executive's Tax & Management Report, Congress may attempt to offset the resulting revenue loss by increased compliance enforcement, more attacks on tax shelters, and rethinking tax deferrals for U.S. firms investing overseas.