Hot Dog Stand Reg Example May Threaten Reverse Morris Trusts

Overview


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.