IRS Opens Up Rulings on Some Device and Business Purpose Issues - McDermott Will & Emery

IRS Opens Up Rulings on Some Device and Business Purpose Issues

Overview


Michael Wilder praised new spinoff-related rules as “a great development,” adding that “the new ruling program will be very attractive even if the market’s gotten comfortable opining on such issues over the last 13 years.” Mr. Wilder suggested that the new ruling authority could mean that the government is “coming up with more specific, defined rules” on other business issues.