Holistic guidance for corporations and their advisers seeking certainty on the tax treatment of their spinoff deals from the IRS is “very far along,” an agency official said.
“It’s an active project, and we want to get it out as soon as possible,” Brian Loss, an IRS senior technician reviewer, said Thursday during a virtual conference hosted by the American Bar Association’s tax section. Still the agency is open to comments from tax professionals on the “one-stop shop” for private letter rulings on tax-free spinoffs, under tax code Section 355, he said.
- The project goes beyond combining ...