At the center of this enforcement initiative is Section 852(b)(6), a specialized nonrecognition provision applicable to regulated investment companies (RICs).
At the center of this enforcement initiative is Section 852(b)(6), a specialized nonrecognition provision applicable to regulated investment companies (RICs).
Through Revenue Ruling 2026-20, the IRS invokes longstanding step-transaction and substance-over-form doctrines to recharacterize so-called "Section 351 conversion transactions" as direct, taxable asset...
Concurrently, Notice 2026-62 serves as a broad warning shot across several other atypical usages of Section 852(b)(6) and multi-position derivative strategies, signaling prospective or retroactive...
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At the center of this enforcement initiative is Section 852(b)(6), a specialized nonrecognition provision applicable to regulated investment companies (RICs). 1, September 28, 2026 Notice 2026-62, 2026-20 I.R.B. Through Revenue Ruling 2026-20, the IRS invokes longstanding step-transaction and substance-over-form doctrines to recharacterize so-called "Section 351 conversion transactions" as direct, taxable asset exchanges under Section 1001.
1, September 28, 2026 Notice 2026-62, 2026-20 I.R.B. Through Revenue Ruling 2026-20, the IRS invokes longstanding step-transaction and substance-over-form doctrines to recharacterize so-called "Section 351 conversion transactions" as direct, taxable asset exchanges under Section 1001.
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