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.
Section 355
Federal Tax ADVISORY: Predecessor and Successor Regulations
There are still many questions about the meaning of the Treasury’s new regulations applying Section 355(e) to predecessors and successors. Our Federal Tax Group examines the answers we do have and what they mean for practitioners.
Read the full advisory here.
Federal Tax Advisory: Private Letter Ruling 201633009
A recent IRS Letter Ruling follows a trend of saying not much of anything. Our Federal Tax Group gleans meaning from this waning source of information.
Click here to read the full advisory.
Federal Tax Advisory: New Spin-Off Regulations Proposed
It could have been worse. Our Federal Tax Group examines the good news and bad news of the Treasury’s latest reinterpretation of Section 355.
Click here to read the full advisory.
Federal Tax Advisory: General Utilities Repeal and Spins
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.