Bob Kane, a JD and Tax LLM alumn recently published an article in Tax Notes that examines whether Example 9 of reg. section 1.1361-5(b)(3) governs the disposition of a qualified subchapter S subsidiary in a nonrecognition transaction.
Bob served as a Tax Court clerk for the U.S. Tax Court from 2012 to 2014. Now, at Ropes & Gray in Boston, he focuses his practice on the tax aspects of domestic and cross-border mergers and acquisitions. He also advises fund sponsors on tax issues in connection with the formation and operation of private investment funds.