IRS No-Rule Policy Will Increase Reliance On Opinions

Law360, New York (February 7, 2014, 10:47 AM EST) -- Recent changes in Internal Revenue Service private letter ruling policy likely will result in greater taxpayer reliance on tax opinions, which may impact certain corporate strategies in the coming year.

Tax-Free Spinoffs

During 2013, the IRS announced two significant changes to its policy on issuing private letter rulings on spinoff transactions intended to qualify as tax-free under Section 355 of the Code.[1]

Background. In a typical spinoff, a corporation distributes to its shareholders (and possibly its creditors), stock (and possibly certain debt securities) of a controlled...
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