Guidance on Spinoff Rulings to Come Next Week?


Philip Levine commented on “the long history” behind expected IRS guidance for its policy on the active trade or business (ATB) requirement first addressed in a 1996 ruling, when he headed the IRS Office of Associate Chief Counsel (Corporate). Mr. Levine said that if the IRS issues guidance similar to that provided in 1996, it “probably would have less effect now given the difference in people’s perception of the need for rulings and IRS’s willingness to issue rulings.”