Several industrial companies have recently implemented transactions to permanently divest legacy contingent liabilities. In these transactions, the divesting company transfers ownership of an entity holding specified legacy...more
1/22/2026
/ Acquisition Agreements ,
Asbestos ,
Asbestos Litigation ,
Buyers ,
Complex Corporate Transactions ,
Corporate Restructuring ,
Corporate Sales Transactions ,
Debt Restructuring ,
Distressed Assets ,
Divestiture ,
Divestment ,
Fraudulent Transfers ,
Insolvency ,
Insurance Claims ,
Investment Funds ,
Liability ,
Mass Tort Litigation ,
Private Equity ,
Private Equity Firms ,
Risk Management ,
Risk Mitigation ,
Settlement
Clients and Friends, As the new year begins, we’re excited to share our 2026 Insights. This issue is packed with analysis and forward-looking commentary on some of the key topics we see shaping the global business landscape....more
1/20/2026
/ Acquisition Agreements ,
Artificial Intelligence ,
Board of Directors ,
Digital Assets ,
Emerging Technologies ,
Global Dealmaking ,
Innovation ,
Investment ,
Litigation Strategies ,
Mass Tort Litigation ,
Merger Agreements ,
Private Equity ,
Regulatory Oversight
On January 16, 2025, the Treasury Department (Treasury) and Internal Revenue Service (IRS) published new proposed regulations related to tax-free spin-offs and split-offs (collectively, spin-offs) and other corporate...more
On May 1, 2024, the Treasury Department (Treasury) and Internal Revenue Service (IRS) released Revenue Procedure 2024-24 (Revenue Procedure), which sets out substantially revised guidelines for private letter ruling (PLR)...more
On January 2, 2024, the Internal Revenue Service (IRS) released two revenue procedures updating the IRS guidelines for private letter ruling (PLR) requests, Revenue Procedure 2024-1 and Revenue Procedure 2024-3 (the 2024...more
On July 26, 2023, the Internal Revenue Service (IRS) Chief Counsel’s Office announced that it would make permanent its pilot program of issuing “fast-track” private letter rulings for requests solely or primarily under the...more
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
7/26/2016
/ Acquisitions ,
Board of Directors ,
Capital Structures ,
Controlled Transactions ,
IRS ,
Recapitalization ,
Safe Harbors ,
Shareholder Distributions ,
Stocks ,
Subsidiaries ,
Tax-Free Spin-Offs
On July 14, 2016, the Internal Revenue Service (IRS) and Treasury Department proposed new Treasury regulations that, if finalized, would generally become effective for distributions under Section 355 of the Internal Revenue...more