Michael Cardella

Skadden, Arps, Slate, Meagher & Flom LLP

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Latest Posts › Internal Revenue Code (IRC)

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New Proposed Regulations Aim To Overhaul Tax-Free Spin-Off Rules

On January 16, 2025, the Treasury Department (Treasury) and Internal Revenue Service (IRS) published new proposed regulations related to tax-free spin-offs and split-offs (collectively, spin-offs) and other corporate...more

1/23/2025 / Compliance , Corporate Taxes , Income Taxes , Internal Revenue Code (IRC) , IRS , Proposed Regulation , Tax Planning , Tax Reform , Tax-Free Spin-Offs , U.S. Treasury

IRS Expands Scope of Private Letter Ruling Program for Spin-Offs and Other Corporate Transactions

On January 2, 2024, the Internal Revenue Service (IRS) released two revenue procedures updating the IRS guidelines for private letter ruling (PLR) requests, Revenue Procedure 2024-1 and Revenue Procedure 2024-3 (the 2024...more

1/9/2024 / Acquisitions , Corporate Governance , Corporate Taxes , Internal Revenue Code (IRC) , IRS , Mergers , Revenue Procedures , Shareholders , Tax-Free Spin-Offs

IRS Makes Permanent Its Fast-Track Corporate Private Letter Rulings

On July 26, 2023, the Internal Revenue Service (IRS) Chief Counsel’s Office announced that it would make permanent its pilot program of issuing “fast-track” private letter rulings for requests solely or primarily under the...more

7/28/2023 / Accounting , Employee Benefits , Fast Track Process , Financial Institutions , Financial Services Industry , Income Taxes , Internal Revenue Code (IRC) , IRS , Pass-Through Entities , Private Letter Rulings

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