Corporate Tax Law Memo

I need a comprehensive tax law memorandum focused on corporate tax compliance and reporting, with a specific emphasis on mergers and acquisitions tax considerations.

Requirements:
- In-depth knowledge of corporate tax law
- Expertise in tax compliance and reporting
- Specialized understanding of mergers and acquisitions tax implications
- Ability to articulate complex tax concepts clearly and concisely
- Experience in legal writing and research

Ideal Skills:
- Tax law degree or equivalent
- Background in corporate taxation, particularly in M&A contexts
- Strong analytical and writing skills
- Prior experience with tax law memoranda

Specifically, this memorandum will address the position taken on treatment of certain disposals as a business item vs portfolio in regards to long term capital gain transactions.

Please provide relevant experience and qualifications in your bids.