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March 06, 2024
Cadwalader partner and Tax Group chair Linda Swartz spoke with Law360 about anticipated new guidance from the IRS about corporate spinoffs, and whether these deals will qualify for tax-free status with more clarity than current regulations, and without the risk of bright-line rules the agency had previously considered.
Among other insights, Linda noted that a big requirement for the IRS to issue timely rulings is having regulations that are specific enough — without resorting to per se rules that are just bright lines — so that representations can be reviewed reasonably quickly.
"The more general the device guidance is, the longer the submission has to be, because the taxpayer and their representatives will want to make sure that they have covered every possible permutation of every requirement," she said.
Read it here (subscription required)
