This recent ruling by the IRS is significant for what it does not say. It does not say much of anything.

It is a “significant issue” ruling, which is a type of limited ruling issued by the Corporate Division of Chief Counsel. The whole statement of facts is as follows:

Taxpayer is a State corporation formed on Date1. Since its incorporation, Taxpayer has engaged in Business. Taxpayer acquired AssetA on Date2, AssetB and AssetC on Date3, AssetD on Date4, AssetE on Date5, and AssetF on Date6 (collectively, the “Acquired Assets”). Taxpayer intends to engage in a divisive reorganization qualifying under sections 368(a)(1)(D) and 355.