LB&I Plans Exams of Spinoff Costs Without Explicit Rules - McDermott Will & Emery

LB&I Plans Exams of Spinoff Costs Without Explicit Rules

Overview


Jay Singer expressed surprise that the IRS Large Business and International Division (LB&I) will pursue enforcement against tax-free distributions in spinoffs, noting that there is insufficient regulatory guidance in this area. The IRS has essentially gone from never providing explicit rules to drawing a line in the sand and going after taxpayers, Mr. Singer stated.