In a client advisory dated February 25, 2016, we described a legal memorandum released by the Office of Chief Counsel of the Internal Revenue Service (the “Memorandum”) which took the position that a typical “carve-out” or...more
The IRS Office of Chief Counsel recently released legal memorandum 201606027 (the “IRS Memorandum” or “Memorandum”) that calls into question two fundamental and well-established aspects concerning the tax treatment of...more