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Corporate Taxes › Active Trade or Business Test › Internal Revenue Service

Wilson Sonsini Goodrich & Rosati

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

Wilson Sonsini Goodrich & Rosati on

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

Wilson Sonsini Goodrich & Rosati

IRS May Relax Collection of Income Prong of Section 355 Active Trade or Business Test for R&D Companies

Wilson Sonsini Goodrich & Rosati on

On September 25, 2018, the Internal Revenue Service (the IRS) released a statement announcing a study of the "active trade or business" test for tax-free spin-offs under Section 355 (the ATB Test), as applied to...more

Pillsbury Winthrop Shaw Pittman LLP

Five Things about the IRS’s Proposed Regulations on the Spinoff Device and Active Business

Pillsbury Winthrop Shaw Pittman LLP on

On July 14, 2016, the Internal Revenue Service (IRS) proposed long-anticipated regulations tightening the “device” and “active trade or business” tests that are necessary for a corporation to distribute a subsidiary in a...more

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