Alston & Bird Tax Blog

Federal Tax Advisory: Split-offs and Device

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Our Federal Tax Group considers ways to pass the inscrutable device prohibition in the Section 355 rules.

  • An “out” from device
  • How about a Morris Trust transaction?
  • Where does the cash come in?

Read the full advisory here.

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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.

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