Try our Advanced Search for more refined results

Expert Analysis

When A Simple Spinoff Is Not Simple

Law360, New York (April 2, 2015, 2:32 PM EDT) -- A recent letter ruling is one of the few "significant issue" rulings issued by the IRS Office of Chief Counsel (Corporate) after it stopped ruling generally on most nonrecognition transactions in Subchapter C. It should have been simple, as spinoffs go, because it was all domestic and involved a pro rata spinoff to public shareholders, where the possibility of "device" is almost nonexistent. And yet, getting to "yes" required a lot of tax engineering....

Law360 is on it, so you are, too.

A Law360 subscription puts you at the center of fast-moving legal issues, trends and developments so you can act with speed and confidence. Over 200 articles are published daily across more than 60 topics, industries, practice areas and jurisdictions.


A Law360 subscription includes features such as

  • Daily newsletters
  • Expert analysis
  • Mobile app
  • Advanced search
  • Judge information
  • Real-time alerts
  • 450K+ searchable archived articles

And more!

Experience Law360 today with a free 7-day trial.

Start Free Trial

Already a subscriber? Click here to login

Related Sections

Law Firms

Government Agencies

Hello! I'm Law360's automated support bot.

How can I help you today?

For example, you can type:
  • I forgot my password
  • I took a free trial but didn't get a verification email
  • How do I sign up for a newsletter?
Ask a question!