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Internal Revenue Code (IRC) Tax-Free Spin-Offs U.S. Treasury

Skadden, Arps, Slate, Meagher & Flom LLP

New Proposed Regulations Aim To Overhaul Tax-Free Spin-Off Rules

On January 16, 2025, the Treasury Department (Treasury) and Internal Revenue Service (IRS) published new proposed regulations related to tax-free spin-offs and split-offs (collectively, spin-offs) and other corporate...more

Cadwalader, Wickersham & Taft LLP

IRS and Treasury Issue Proposed Regulations on Tax-Free Reorganizations, Spin-Offs

On January 13, the U.S. Treasury and Internal Revenue Service released long-awaited proposed regulations governing the treatment of certain features of tax-free corporate spin-off and split-off transactions.  The IRS and...more

Wilson Sonsini Goodrich & Rosati

IRS Proposes Tax-Free Spin-Off Regulations Interpreting the "Device" and "Active Business" Tests and Addresses Recapitalizations...

On July 14, 2016, the U.S. Department of the Treasury issued proposed regulations under Section 355 of the Internal Revenue Code that would establish new guidelines under the so-called "device" and "active business" tests....more

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