Linda Carlisle's Comments During PLI Conference Covered in Tax Notes

"IRS Concerned by Aggressive Exchange Rights in Up-Cs, Up-REITs"
Tax Notes
12.04.15

Linda Carlisle's comments regarding the 60-day notice period for exchange rights provided in section 7704 were published in Tax Notes. Carlisle made the comments during a panel discussion at the Practising Law Institute's Tax Strategies for Corporate Acquisitions, Dispositions, Spin-Offs, Joint Ventures, Financings, Reorganizations & Restructurings Conference The panel, which featured Clifford Warren, special counsel, Internal Revenue Service Associate Chief Counsel, addressed passthrough corporations and publicly traded partnerships (PTPs).

Carlisle's comments were noted again in Tax Notes on December 7, 2015, in an article titled "Aggressive Exchange Rights in Up-Cs, Up-REITs Concern IRS."

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