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Purchasing shares with exchangeable debt and ending up empty handed

Baker McKenzie

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USA December 20 2012

In Office of Chief Counsel memorandum AM2012-007, the Office of Chief Counsel advised the Large Business & International Division (LB&I) to ignore subsidiary stock that a corporation (“Parent”) had purportedly purchased in determining whether the subsidiary was affiliated with Parent under Code Section 1504(a).

Content is provided for educational and informational purposes only and is not intended and should not be construed as legal advice. This may qualify as "Attorney Advertising" requiring notice in some jurisdictions. Prior results do not guarantee similar outcomes. For more information, please visit: www.bakermckenzie.com/en/client-resource-disclaimer.

Baker McKenzie - Seth Pardee

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