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Jaburg Wilk

Tax Relief to Help Weather the Storm of COVID-19

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As the COVID-19 pandemic has wreaked havoc on our personal, financial and business lives, the government has responded with legislative and administrative relief.  This is a high-level summary of some of the enacted measures...more

Alston & Bird

Dual-Class Stock Blessed for Spin

Alston & Bird on

A new Letter Ruling from the IRS brings concerns for corporations looking at a spinoff. Our Federal Tax Group breaks down the guidelines and what they mean. - Dual-class structure - Debt - Delayed transfers LTR...more

Kramer Levin Naftalis & Frankel LLP

Funds Talk: June 2017 - The IRS Resumes Issuing Private Letter Rulings on ‘Leveraged’ and ‘North-South’ Spinoffs

Kramer Levin Naftalis & Frankel LLP on

The IRS announced in May that it will resume issuing private letter rulings (PLRs) on two types of spinoff transactions — leveraged spinoffs and north-south spinoffs — that had been on its “no-rule” list since 2013. In a...more

Morrison & Foerster LLP

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

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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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