News Analysis: The Spin Cycle Goes Global Again


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.