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Corporate Taxes › Tax-Free Spin-Offs › Private Letter Rulings

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

Bracewell LLP

Bracewell Tax Report - January 2019

Bracewell LLP on

The Bracewell Tax Report is a periodic publication focused on developments in federal income tax law, including the recently enacted Tax Cuts and Jobs Act, with emphasis on how such developments impact the energy, technology...more

Proskauer - Tax Talks

Tax Planning is Crucial to Achieve Potential Spin-Off Benefits

Proskauer - Tax Talks on

Today, the Wall Street Journal considers again, on its front page above the fold, the potential benefits of corporate spin-off transactions. The Journal article notes that the S&P Spin-Off Index has outperformed the S&P 500...more

Jones Day

IRS Opens Pilot Program on Tax-free Spin-offs

Jones Day on

The Situation: In 2013, the IRS ceased issuing private letter rulings confirming the general tax consequences of tax-free spin-offs....more

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