IRS ‘Open for Business’ for Corporations’ Spinoff Rulings - McDermott Will & Emery

IRS ‘Open for Business’ for Corporations’ Spinoff Rulings

Overview


Jay Singer discussed a situation under a recent IRS north-south revenue ruling which presents interesting questions for consolidated returns, specifically when the north-south transaction moves down a level and occurs between the distributing and controlled corporations. The IRS position in such situations has the potential to be adverse for consolidated groups, Mr. Singer said.