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Internal Revenue Service › Controlled Transactions

The United States Internal Revenue Service is a bureau of the United States Department of the Treasury. The IRS is charged with collecting revenue and enforcing the Internal Revenue Code.  
Farrell Fritz, P.C.

Determining The Appropriate Fee For Services Rendered To A Related Company

Farrell Fritz, P.C. on

This week, we return to two recurring themes of this blog: (I) related party transactions – specifically, transactions between a taxpayer and a corporation controlled by the taxpayer; and (II) what happens when a taxpayer...more

Jones Day

IRS Will Resume Ruling on Important Spin-Off Issues

Jones Day on

The IRS recently provided taxpayers with favorable guidance involving tax-free spin-offs. First, the IRS will resume issuing private rulings that allow a distributing corporation to satisfy debt it issued in anticipation of a...more

Skadden, Arps, Slate, Meagher & Flom LLP

"IRS Offers Limited Safe Harbors for Recapitalizations Before Spin-Offs"

Skadden, Arps, Slate, Meagher & Flom LLP on

On July 15, 2016, the Internal Revenue Service (IRS) released a new revenue procedure, Rev. Proc. 2016-40, providing safe harbors for transactions in which a corporation (Distributing) obtains the requisite control of a...more

Skadden, Arps, Slate, Meagher & Flom LLP

"New Regulations Address Outbound Transfers and Transfer Pricing"

Skadden, Arps, Slate, Meagher & Flom LLP on

On September 14, 2015, the Internal Revenue Service (the IRS) and Treasury Department proposed new regulations addressing the tax treatment under Section 367 of the Internal Revenue Code (the Code) of certain transfers by...more

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