Select a locationselect a location

Articles

Search Articles
Search by date
Choose From Date
Choose To Date
SearchClear

A Gambit Vanquished:  The Rise and Fall of the 'Killer B'

2011

52 Tax Management Memorandum 419
Reprinted with permission from Tax Management Memorandum

Resources

On May 19, 2011, the Internal Revenue Service and the Treasury Department published final Treasury regulations that are designed to shut down what have become known as "Killer B" transactions. These transactions oftentimes involve a foreign subsidiary purchasing stock or securities of its domestic parent corporation in exchange for property, and thereafter exchanging the parent corporation stock or securities for the stock, securities or property of a foreign target corporation in a triangular reorganization.

In the article "A Gambit Vanquished: The Rise and Fall of the 'Killer B,'" Sutherland Tax Attorneys William R. Pauls and H. Karl Zeswitz Jr. explore the technical underpinnings of a "Killer B" transaction, examine the guidance that set the stage for the issuance of the final Treasury regulations and offer a critique of those regulations. To read their article, which was published in the October 10, 2011, issue of Tax Management Memorandum, click here.

Related Practices/Industries

Our Story

Eversheds Sutherland is an international law firm helping the Fortune 100, industry leaders, sector innovators and business entrepreneurs solve their biggest challenges and reach their business goals. Dedicated to unfaltering excellence in client service, we are known for our business savvy and industry intelligence, providing creative and custom solutions for each of our clients. Industry and business experience makes the difference for our clients.

click to watch Videocast: FINRA’s 2016 Disciplinary Program:  “YUUUGE” Fines May Propel 2016 to Record-Setting Year
Videocast: FINRA’s 2016 Disciplinary Program:  “YUUUGE” Fines May Propel 2016 to Record-Setting Year
Washington, DC
Adam C. Pollet, Associate
Washington, DC
© 2017 Eversheds Sutherland (US) LLP
MYBRIEFCASE
Add this page to MYBRIEFCASE
Add Page to MYBRIEFCASE
News/Commentary - A Gambit Vanquished:  The Rise and Fall of the 'Killer B'
Current MYBRIEFCASE Pages
Save ChangesDownload MYBRIEFCASEClear All