IRS allows Section 338(g) election when foreign securities compliance decreased ownership below 80% *

USA - June 19 2012
In a PLR issued on April 20, 2012, the IRS has ruled that an affiliated group could make a Code Section 338(g) election despite owning less than 80% of a foreign target when the decreased ownership resulted from compliance with the foreign country’s securities laws.

IRS issues final regulations for cost sharing arrangements *

USA - February 22 2012
On January 9, 2012, the North America Tax Practice Group distributed a Client Alert discussing the final regulations for cost sharing arrangements under Code Section 482 ("Final Regulations"), which were issued by the Treasury on December 16, 2011.

Co-authors: Ivan A. Morales.