On September 25, 2018, the Internal Revenue Service (the IRS) released a statement announcing a study of the "active trade or business" test for tax-free spin-offs under Section 355 (the ATB Test), as applied to...more
On May 3, 2017, the IRS released Revenue Ruling 2017-9, which addresses two so-called "north-south" transactions in connection with spin-offs that are intended to be nontaxable under Section 355 of the Internal Revenue Code....more