IRS PLR: Corporate Reorganization Transaction Rulings Issued (IRC §368)

The IRS issued 15 rulings on a corporate reorganization pursuant to which, among other steps: “Distributing” contributed all of its interests in four disregarded entities and three subsidiaries to “Controlled” in exchange for Controlled stock, more than 80% of which it will distribute to Distributing shareholders either as a pro rata dividend in a spin-off or in exchange for shares of Distributing common stock in a split-off (“Initial Distribution”); and Distributing may transact with investment bank(s) in certain “Debt Exchanges” involving “Distributing Exchange Debt.” (1) Contribution, along with Initial Distribution and any subsequent distribution, will be a “reorganization” within the ...