The Internal Revenue Service has announced that it will recommence issuing private letter rulings concerning whether a distributing corporation’s transfer of stock or securities of a controlled corporation (or “Spinco”) in...more
In this issue:
- District Court Protects Opinion Work Product Contained in Tax Accrual Workpapers in Wells Fargo
- IRS Restricts Private Letter Rulings for Spin-Offs and Other Corporate Nonrecognition...more