The U.S. IRS, on July 29, released an advance copy of Notice 2014-45, which expands on Notice 2014-44, released its July 21, concerning dispositions of assets following a section 901(m) covered asset acquisition. Notice 2014-45 provides that, to prevent abuse, the IRS will draft regulations providing that the rules set forth in the Notice 2014-44 will apply to entity classification elections filed on or after July 29 that are effective for dates preceding July 21. Notice 2014-15, related coverage
