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Tax Planning Spinoffs Corporate Taxes

Latham & Watkins LLP

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

Latham & Watkins LLP on

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

Cadwalader, Wickersham & Taft LLP

Treasury Official Indicates New Taxpayer Friendly Spin-Off Regulations are Coming—But No Change in Ruling Policy in the Meantime

At a recent conference of the American Bar Association, Treasury Associate Tax Legislative Counsel Colin Campbell Jr. stated that the recent proposed regulations governing corporate spin-off and reorganization...more

Jones Day

New Proposed Regulations Address Spin-Off Transactions

Jones Day on

These proposed regulations applicable to tax-free spin-offs would impose a range of new substantive requirements and greatly expand the information that must be reported to the Internal Revenue Service ("IRS") by taxpayers...more

Jones Day

New Fast-Track IRS Guidance for Spin-Offs and Other Corporate Transactions

Jones Day on

On January 14, 2022, the Internal Revenue Service ("IRS") released Revenue Procedure 2022-10, which establishes a "fast-track processing" pilot program for certain private letter ruling requests that are solely or primarily...more

Cadwalader, Wickersham & Taft LLP

Breaking Up: Case Study on GE’s Proposed Spin-Offs

The Cadwalader Tax team has prepared a case study summarizing General Electric’s recently announced plans to split into three publicly traded companies through sequenced tax-free spin-off transactions. ...more

Cadwalader, Wickersham & Taft LLP

A Peek Behind the Curtain: IRS Musings on Spinoff Ruling Procedures

Speaking at several tax conferences this month, several senior IRS officials, including the Associate Chief Counsel, Corporate, discussed the nuances of the device requirement for spinoffs and signaled a willingness to relax...more

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