Layla Asali Quoted Regarding Guidance Targeting Covered Asset Acquisitions in Tax Notes Today

"Narrow FTC Guidance Targets Avoidance Transactions"
Tax Notes Today
07.22.14Layla Asali was quoted regarding recently released guidance regarding dispositions of assets following covered asset acquisitions under section 901(m). Asali said Notice 2014-44 targets a "narrow point" under section 901(m) that needed to be addressed. "But of course, I would have been hopeful that we would get broader 901(m) guidance," she said. Asali said the definitional issue addressed in the notice could have been addressed in broader guidance. "This notice is framed as an antiabuse rule. They indicate a transaction that taxpayers were undertaking that the government was concerned about," she said. The notice makes clear that the government does not believe the rules work the way taxpayers have been applying them, she added, and it may seek to challenge transactions under existing law.
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