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Section 355

Federal Tax Advisory: Split-offs and Device

March 5, 2019 By Jasper L. (Jack) Cummings, Jr.

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.

Filed Under: Federal Tax Advisory Tagged With: Section 355

Federal Tax ADVISORY: Predecessor and Successor Regulations

February 1, 2017 By Jasper L. (Jack) Cummings, Jr.

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. 

Filed Under: Federal Tax Advisory Tagged With: controlled corporation, distributed corporation, Section 351, Section 355, Section 381, Treasury

Federal Tax Advisory: Private Letter Ruling 201633009

September 1, 2016 By Jasper L. (Jack) Cummings, Jr.

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.

Filed Under: Federal Tax Advisory Tagged With: Corporate Division of Chief Counsel, IRS, Section 355, Section 368(a)(1)(D)

Federal Tax Advisory: New Spin-Off Regulations Proposed

August 1, 2016 By Jasper L. (Jack) Cummings, Jr.

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.

Filed Under: Federal Tax Advisory Tagged With: active trade, ATB, business assets, device factor, IRS, nondevice factors, Reg. Section1.355-2(d), safe harbor, Section 355, Treasury

Federal Tax Advisory: General Utilities Repeal and Spins

May 2, 2016 By Jasper L. (Jack) Cummings, Jr.

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.

Filed Under: Federal Tax Advisory Tagged With: federal and international tax, federal tax, General Utilities Doctrine, international tax, IRS, Notice 2015-40 IRB459, Notice 2015-59, Section 355, tax deferred, utilities

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