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"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

"House Ways and Means Committee’s Tax Reform Proposals for Financial Products"

On January 24, 2013, Rep. Dave Camp (R-Mich), the chairman of the House Ways and Means Committee, released a “discussion draft” of a bill relating to the taxation of derivatives and other financial products (the Discussion...more

1/29/2013 - Debt-Relief Industry Derivatives Discussion Draft Market Discount Rules Restructuring Wash Sale Rules Ways and Means Committee

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