Recent IRS guidance reduces the minimum aggregate amount of cash required for certain distributions of stock and cash to qualify for the dividends paid deduction.
In order to enhance liquidity of publicly offered real...more
The new guidance is significant given the popularity of debt exchanges as a monetization technique in conjunction with spin-offs.
On October 3, 2018, the Internal Revenue Service (IRS) published Revenue Procedure 2018-53,...more
Revenue procedure sets forth requirements for ensuring certain stock distributions are treated as property distributions eligible for dividends paid deduction.
On August 11, 2017, the Internal Revenue Service (IRS)...more