IRS Issues PLR Confirming Tax-Free Spin-Off, Subsequent Merger

The IRS has issued a private letter ruling on I.R.C. §355 confirming a series of tax-free corporate separations in which Distributing will transfer SpinCo Business assets to Controlled 1 followed by distribution of Controlled 1 stock to shareholders and subsequent merger with Acquiring, with Distributing shareholders owning approximately 1 percent of the combined company after the transaction. [PLR 202616004]

This story was produced by Bloomberg Tax Automation, and edited by Bloomberg Tax staff.