IRS ‚North-South‘ Spinoff Ruling Good News, Practitioners Say


Jay Singer called a new IRS ruling on so-called “north-south” spinoff transactions under Section 355 ”definitely great news for taxpayers” because it provides a high level of assurance that taxpayers will have a tax-free transaction. Since 2013, he continued, prior guidance from the IRS on these transactions was “scant and not taxpayer friendly.”