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Revenue Procedures Tax-Free Exchanges

Latham & Watkins LLP

IRS Publishes Ruling Requirements for Certain Tax-Free Spin-Off Monetization Transactions

Latham & Watkins LLP on

The new guidance is significant given the popularity of debt exchanges as a monetization technique in conjunction with spin-offs. On October 3, 2018, the Internal Revenue Service (IRS) published Revenue Procedure 2018-53,...more

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