IRS Spinoff Proposal Timeline Murky, But Will Mirror Notice

Proposed regulations on tax-free corporate spinoff transactions will address questions that arose from notices the IRS issued earlier this year.

The release date, however, remains unclear.

Jonathan Neuville, senior technical reviewer in the office of associate chief counsel at the IRS, told the New York University School of Professional Studies Institute on Federal Taxation conference on Tuesday that the long-awaited proposed regulations will focus on issues set forth in Notice 2024-38 posted in May.

An IRS revenue procedure in May put stricter limits on tax-free spinoffs and curtailed private letter rulings.

The upcoming provisions could lay out how parent companies ...