By Laurence Stein, Pardis Zomorodi and William Kessler ( October 25, 2018, 2:15 PM EDT) -- On Oct. 3, 2018, the Internal Revenue Service published Revenue Procedure 2018-53, which, among other things, sets forth requirements to request a private letter ruling regarding certain tax-free spinoff transactions in which the distributing corporation, or parent, uses stock or securities of the controlled corporation, or spinco, to repay the parent's debt, in the form of stock-for-debt or debt-for-debt exchanges.[1] The new guidance is significant given the popularity of debt exchanges as a monetization technique in conjunction with spinoffs....
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