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Corporate Taxes › Reorganizations › Spinoffs

Miller Nash LLP

Today in Tax: IRS Introduces Fast-Track Process for Obtaining Letter Rulings

Miller Nash LLP on

Corporate reorganizations and spin-off transactions are transactions where there is often a great deal of incentive to qualify for tax-free treatment. In many cases, the amount of tax at issue justifies obtaining a private...more

Cadwalader, Wickersham & Taft LLP

Proposed Regulations Would Block Some Spinoffs

Cadwalader, Wickersham & Taft LLP on

Proposed regulations issued on July 14, 2016 generally would prevent tax-free spinoffs involving companies with less than 5% active business assets and spinoffs where one company holds a substantial amount of nonbusiness...more

Alston & Bird

A Reverse Morris Trust Ruling

Alston & Bird on

LTR 201542004 at first seems to involve a standard spinoff for the purpose of pursuing a reverse Morris Trust combination of Controlled with a Merger Partner, with the “significant issue” for ruling being a proposed swap of...more

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