Guidelines Placed on Control Workarounds for Spinoffs


Jay Singer said new IRS guidance on creating safe harbors for corporate tax-free spinoffs is helpful in that “it enables us as tax lawyers to do what we rarely get to do, which is actually give our clients a clear answer to a question they ask us. Now you can say, ‘Wait two years,’” the period of time set by the IRS to determine if control of the spinoff actually has transferred.