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Demystifying Spinoffs: Complex “IPOs” With a Sophisticated Tax Overlay

In a spinoff, a public company separates one or more of its businesses into a new, publicly traded company. For the public company that initiates it, a spinoff can achieve a number of critical business and financial...more

IRS Publishes Ruling Requirements for Certain Tax-Free Spin-Off Monetization Transactions

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

IRS Studying Active Trade or Business Requirement for Tax-Free Spin-Offs

The IRS is considering future guidance that could present opportunities for R&D phase businesses. In a statement issued on September 25, 2018, the Internal Revenue Service (IRS) announced that it is studying the active...more

IRS Adds Certain Spin Transactions to the “No Rule” List

Treasury and IRS announce that certain “cash rich” and REIT/RIC conversion spin-offs are under study and are added to the “no rule” list. On September 14, 2015, the United States Treasury Department (the Treasury) and...more

10/1/2015  /  IRS , REIT , RICs , Shareholders , Spinoffs , U.S. Treasury
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