The recent guidance under section 355 is a significant attempt by the IRS to clarify in a formal way what it historically has been able to do on a case-by-case basis through the private letter ruling ...

The active trade or business rules are detailed and highly fact specific, and the IRS continues to refine its view on the qualification requirements. In order to separate two businesses housed in one ...

We collaborate with the world's leading lawyers to deliver news tailored for you. Sign Up for any (or all) of our 25+ Newsletters. Some states have laws and ethical rules regarding solicitation and ...

A tax-free spinoff allows a company to create a new entity without incurring capital gains tax. Shareholders receive shares in the new company in proportion to their equity in the parent. Spinoffs may ...

The Internal Revenue Service announced a number of changes to how it will process private letter rulings related to a handful of corporate transactions. Processing Content The agency said in a ...