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McDermott Will & Emery

Weekly IRS Roundup March 25 – 29, 2019

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Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of March 25 – 29, 2019. March 25, 2019: The IRS issued Proposed Regulations under Section 301 of...more

A&O Shearman

IRS Expands Scope of Spin-Off Private Letter Rulings in 18-Month Pilot Program

A&O Shearman on

On September 21, 2017, the IRS announced in Revenue Procedure 2017-52 (the “Pilot Program Rev. Proc.”) that it is expanding the scope of spin-off private letter ruling requests that it will consider. The pilot program is...more

Dechert LLP

Part Cash, Part Stock, 100% Taxable – New IRS Guidance on RIC and REIT Distributions

Dechert LLP on

The U.S. Internal Revenue Service (“IRS”), on August 11, 2017, issued Revenue Procedure 2017-45 (the “New Revenue Procedure”).1 Pursuant to the New Revenue Procedure, the IRS will treat part cash and part stock distributions...more

Morrison & Foerster LLP

New IRS Guidance Limits Tax-Free Spin-Off Rulings – Implications for REIT Spin-Offs

Morrison & Foerster LLP on

On September 14, 2015, the Internal Revenue Service (“IRS”) issued Notice 2015-59 (the “Notice”) and Revenue Procedure 2015-43 (the “Rev Proc”; together with the Notice, the “Spin-Off Guidance”). Under the Spin-Off Guidance,...more

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