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Principal Tax Issues in Debt Restructurings

As a result of the current difficult economic environment, many debtors and lenders find themselves in the position of having to renegotiate and restructure their debt obligations and entitlements. Without careful upfront tax...more

5/4/2020  /  Corporate Taxes , Debt , IRS

IRS Ruling May Further Signal a Relaxation of “Collection of Income” Prong of Tax-Free Spin-off Active Trade or Business Test

On February 28, 2020, the Internal Revenue Service (IRS) released private letter ruling 202009002 (the PLR), which concluded that an absence of income does not, under the facts of the PLR, prevent a line of business from...more

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