IRS PLR: Series of Transactions Qualify as Tax-Free Reorganizations, Distributions (IRC §355)

The IRS has published a private letter ruling on Section 355, Section 361, and Section 368 regarding a series of proposed transactions in which distributing parent, a publicly traded and widely held corporation, will separate two businesses pursuant to an overall plan of reorganization. The proposed internal spin-offs will qualify as tax-free reorganizations under Section 368(a)(1)(D) and Section 355, and as a tax-free distributions under Section 355. The proposed external spin-off involving the distributing parent will qualify as a tax-free reorganization under Section 368(a)(1)(D) and Section 355. [PLR 202339007]

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