Overview
Timothy Shuman said he would like to see IRS guidance on how multiple acquisitions are counted for purposes of Section 355(e) relating to spin-offs. “There is uncertainty in any complex fact pattern involving multiple acquisitions or share repurchases,” Mr. Shuman said, citing difficult questions about how repurchases are taken into account in determining the 50 percent change in control required under Section 355(e) when a company undertakes a spinoff.
