IRS Expands Letter Ruling Program for Some Spinoff Transactions - McDermott Will & Emery

IRS Expands Letter Ruling Program for Some Spinoff Transactions

Overview


Timothy Shuman called new IRS for transactional rulings regarding some tax-free spinoff transactions under section 355 “a great development in that it opens back the ruling program to more spin rulings” by defining the level of documentation needed. The result “provides a streamlined process for going in for a ruling,” Mr. Shuman added.