IRS Will Rule on Debt Exchanges in Leveraged Spinoffs


Jay Singer said that, although the IRS removed leveraged spinoffs from the no-rule list without issuing guidance, it’s a reasonable policy decision that makes sense administratively if the IRS decided that it’s “hard to write one-size-fits-all guidance” for those large transactions and best to issue rulings before taxpayers execute the transactions. He added that the interesting question is what guidelines the IRS will use in future letter rulings.