Further Broad Spinoff Rules Aren’t Planned, IRS Official Says

Jan. 13, 2026, 7:53 PM UTC

The IRS and the Treasury Department aren’t planning any further broad guidance on tax-free corporate spinoffs to replace proposed regulations that are being withdrawn, an IRS official said Tuesday.

Instead, the IRS is encouraging companies to seek individual private letter rulings to get approval for their transactions, said Robert Liquerman, special counsel in the IRS Office of Associate Chief Counsel (Corporate), speaking at the New York State Bar Association’s annual meeting. PLRs are company-specific pre-approvals of a company’s actions from a tax perspective.

“We are open for business. We want people to come in,” Liquerman said.

He also said the ...

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