Hot Dog Stand Reg Example May Threaten Reverse Morris Trusts


Jay Singer told a District of Columbia Bar Taxation Section meeting that, before the IRS issued new regulations on internal spinoffs that occur in preparation for an external spinoff, he believed the government was « inclined to be more flexible when it came to internal spinoffs from lower-tier entities. » But the new regulations make clear that any sympathy the government might once have had for those transactions is gone, Mr. Singer concluded.