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Final Regulation Clarify Liability Treatment in Intragroup Section 351 Transactions
The Treasury Department and IRS have issued final regulations clarifying the treatment of certain liabilities in intragroup Section 351 transactions. The guidance provides important insight into subsidiary stock basis calculations, excess loss accounts, and internal restructuring transactions within consolidated groups.
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Preparing for a Successful OneStream Implementation: 4 Decisions to Make Before Kickoff
The foundation for a successful OneStream implementation is built before the project begins. Learn four practical considerations that can help align stakeholders, improve adoption, and support long-term Finance transformation.
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Technical Update: When Public Groups Collide – Actual Knowledge and the Limits of Section 382 Segregation
A recent IRS private letter ruling provides important guidance on establishing “actual knowledge” of overlapping public shareholders for purposes of Section 382 ownership change analyses. This article explores the ruling’s implications and how detailed ownership analysis may help preserve valuable tax attributes.
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WilliamsMarston places client success at the heart of everything we do. From dedicated senior-level involvement in every engagement to specialized teams, our accounting, tax, technology, transaction and valuation experts pair Big Four experience with strong technical expertise to deliver unparalleled perspective, practical advice and effective solutions that accelerate impact.
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Gain the insight to drive transformational outcomes. WilliamsMarston’s accounting, tax, technology, transaction and valuation services will help you navigate your most complex challenges and see you through to success.