The new IRS ruling policy on spin-off transactions Davis J. Wang.; Jameson S. Lloyd.; M. John Jo.; Stephen J. Profeta.
By: Wang, Davis J
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Contributor(s): Lloyd, Jameson S | Jo, M. John | Profeta, Stephen J.
Material type: 
ArticleSubject(s): DEUDA TRIBUTARIA | EMPRESAS | ESCISIÓN
In:
Journal of Taxation of Investments n. 41-4, Summer 2024 , p. 39-45Summary: On May 1, 2024, the IRS issued Revenue Procedure 2024-24, which establishes revised standards for taxpayers seeking private letter rulings on tax-free spin-offs, focusing in particular on, among other things, issues relating to stock-for-debt exchanges and debt securities-for-debt exchanges occurring in connection with tax-free spin-offs. Such debt exchanges have been a popular feature in many spin-off transactions as a tax-efficient way for companies to de-lever by effectively reallocating parent company debt to the company being spun-off. Administrative guidance on such exchanges has evolved over the years, and the new Revenue Procedure signals a significant departure from recent ruling practices.
| Item type | Current location | Home library | Call number | Status | Date due | Barcode |
|---|---|---|---|---|---|---|
| Artículos | IEF | IEF | OP 235/2024/4-3 (Browse shelf) | Available | OP 235/2024/4-3 |
On May 1, 2024, the IRS issued Revenue Procedure 2024-24, which establishes revised standards for taxpayers seeking private letter rulings on tax-free spin-offs, focusing in particular on, among other things, issues relating to stock-for-debt exchanges and debt securities-for-debt exchanges occurring in connection with tax-free spin-offs. Such debt exchanges have been a popular feature in many spin-off transactions as a tax-efficient way for companies to de-lever by effectively reallocating parent company debt to the company being spun-off. Administrative guidance on such exchanges has evolved over the years, and the new Revenue Procedure signals a significant departure from recent ruling practices.
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