Listed Transaction (LT #11)
MIDCO Deals (Agency & Intermediary Corp. Abuses)
IRS Notice 2001-16
Here, the IRS is concerned about principles of agency (i.e., whether Midco (M) is really acting as agent for either X or Y, nothing more than an intermediary).
If you believe that you may have engaged in a transaction that is the same or substantially similar to the transaction described above, Federal law may require you to disclose your and other parties' participation in any such "listed transaction" on IRS Form 8886. For more information about Federal law requirements, please contact us.
