Compliance Concerns Fueled Mechanical Spinoff, Debt-Equity Regs


Philip Levine said new Section 355 and 385 rules shift reporting from a weighing to a mechanical approach. “An area that had been determined pretty much exclusively by facts and circumstances is now being looked at as something that can be quantified to a degree,” Mr. Levine explained. “One sense is that it’s because of policy concerns that it’s moving in this direction — not wanting taxpayers to be able to argue their way out of situations that the government is troubled by.”