Matthew Rosen

"New Section 355 No-Rule Policies"

On January 2, 2013, the Internal Revenue Service (the Service) released Rev. Proc. 2013-3, its annual list of areas in which it no longer will issue private letter rulings or determination letters (the 2013 No-Rule List). Of...more

2/13/2013 - 2013 No-Rule List Debt Securities Debt-for-Debt Exchanges IRS North-South Transactions Private Letter Rulings Recapitalization Section 355 Shareholders Spinoffs Stocks