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Revenue Procedures Taxable Distributions

McDermott Will & Emery

Weekly IRS Roundup August 17 – August 21, 2020

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Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of August 17, 2020 – August 21, 2020... August 19, 2020: The IRS requested comments from large...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

Alston & Bird

Qualification of Certain Section 355 Spinoff Transactions Added to No-Rule List as IRS and Treasury Study the Topic

Alston & Bird on

On September 14, 2015, the government released Notice 2015-59 and Rev. Proc. 2015-43, both relating to Section 355 spinoffs. They respond to government concerns about spinoff transactions that result in the distributing...more

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