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Holland & Knight LLP

Section 1202 Gross Assets and Basis Issues for Qualified Small Business Stock

Holland & Knight LLP on

In order for stock to be qualified for an exclusion on gain under Internal Revenue Code (Code) Section 1202, the issuing corporation must, among other requirements, have aggregate gross assets of no more than $75 million at...more

Skadden, Arps, Slate, Meagher & Flom LLP

"Proposed Treasury Regulations Raise New Hurdles for Tax-Free Spin-Offs"

Skadden, Arps, Slate, Meagher & Flom LLP on

On July 14, 2016, the Internal Revenue Service (IRS) and Treasury Department proposed new Treasury regulations that, if finalized, would generally become effective for distributions under Section 355 of the Internal Revenue...more

Pillsbury Winthrop Shaw Pittman LLP

Five Things about the IRS’s Proposed Regulations on the Spinoff Device and Active Business

Pillsbury Winthrop Shaw Pittman LLP on

On July 14, 2016, the Internal Revenue Service (IRS) proposed long-anticipated regulations tightening the “device” and “active trade or business” tests that are necessary for a corporation to distribute a subsidiary in a...more

Eversheds Sutherland (US) LLP

To the Direct Acquirer Belong the Tax Attributes: Proposed Regulations Modify the Definition of Acquiring Corporation for Purposes...

Eversheds Sutherland (US) LLP on

On May 7, Treasury and the IRS published proposed regulations addressing which corporation succeeds to the tax attributes of another corporation that transfers assets in an acquisitive asset reorganization described in IRC §§...more

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