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Spinoffs Internal Revenue Code (IRC) Tax-Free Spin-Offs

Jones Day

New Proposed Regulations Address Spin-Off Transactions

Jones Day on

These proposed regulations applicable to tax-free spin-offs would impose a range of new substantive requirements and greatly expand the information that must be reported to the Internal Revenue Service ("IRS") by taxpayers...more

A&O Shearman

Proposed regulations provide guidance regarding certain aspects of spinoffs and reorganizations

A&O Shearman on

On January 13, 2025, the U.S. Treasury Department (the “Treasury”) and the Internal Revenue Service (the “IRS”) issued proposed regulations (REG-112261-23 and REG-112261-24) adding and amending parts of the regulations...more

Bracewell LLP

Spin Me Right Round: Recent Developments Impacting Tax-Free Spin-Offs

Bracewell LLP on

In our recent article on spin-offs (click here), we discussed an announcement made by the Internal Revenue Service (IRS) signaling a change in the application of the active trade or business (ATB) requirement under Section...more

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