Our Federal Tax Group notes IRS concerns about Section 355 tax-deferred spinoffs, including the relevance of the 1986 repeal of the General Utilities doctrine.
Click here to view the entire advisory on the Alston & Bird website.
About Jasper L. (Jack) Cummings, Jr.
Jack Cummings is counsel in the Federal Tax Group of Alston & Bird in Raleigh and Washington, D.C. He served as IRS associate chief counsel (corporate) and chair of the Corporate Tax Committee of the ABA Section of Taxation.