Alexander Sheds Light on Meaning of No-Rule's 'in Anticipation of' a Spinoff - McDermott Will & Emery

Alexander Sheds Light on Meaning of No-Rule’s ‘in Anticipation of’ a Spinoff

Overview


Philip Levine, assessing possible IRS guidance on north-south transactions (where a contribution and subsequent distribution may or may not be integrated as an exchange), said he’s skeptical of the prospects for such guidance because the issues are fact-based and may depend on the circumstances of a particular transaction.