The potential broad applicability of recent guidance addressing situations in which a shareholder’s stock has split holding periods and split basis continues to alarm practitioners, in part because of anomalies in the cross-border context. The IRS has cautioned practitioners against thinking that a May 2020 generic legal advice memorandum (AM 2020-005) applies narrowly or applies too broadly, leaving some pondering the meaning of specific language.
A&M's Kevin M. Jacobs shares his perspective with Tax Notes.
READ THE FULL ARTICLE HERE.
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