355 tax-free spin-off. The new rules also address whether a corporation is engaged in a trade or business through attribution of trade or business assets and activities from a partnership.EBSCO_bspFederal Tax Course Letter
A tax-free spinoff refers to a corporate action in which a publicly traded company spins off one of its business units as an entirely new company without tax implications. This type of transaction is deemed to be "tax-free" because the parent company is still able to divest the business i...
If enacted in its present form, the Build Back Better Act (BBBA) would amend the U.S. tax code’s rules for tax-free spin-off and split-off transactions (spin-offs), imposing significant restrictions on a parent company’s ability to reallocate debt to the spin-off company withou...
In its operational, regulatory and strategic complexity, a tax-free spin-off is something of a three-part challenge: as demanding as any business carve-out, with added requirements akin to those of an IPO, plus the close involvement of tax authorities and the SEC. In assessing the most crit...
Tax-free spin-off of the United States Public Sector business of DXC Technology Tax-free spin-off of the Powertrain Systems Segment of Delphi Automotive to its shareholders Tax-free spin-off by Archrock, Inc. of Exterran Corporation to its shareholders Acquisition by LogMeIn of the GoTo business...
Moving back to the system of territorial taxation for individuals would be fair and would stem the flow of American citizens renouncing their citizenships. …the US system of global individual taxation creates undue burdens for individuals seeking to make a living abroad. …Tax compliance rules driv...
or events (but excluding the Distribution)), or (C) take any other act, if the act described in each of clause (A), (B) or (C) above would be inconsistent with the Spin-Off Representation Letter or the intended tax-free treatment of the Distribution to holders of HEI Common Stock de...
April 1, 2025 Line items Prop. regs. address expanded annual compensation deduction limitation … Prop. regs. issued for spinoff transactions and their reporting … Regs. identify microcaptive transactions as reportable transactions … IRS proposes new rules for tax professionals … IRS proposes new ...
Tax and transactional lawyers collaborate on structuring, negotiating and executing taxable and tax-free transactions that include domestic and cross-border mergers and acquisitions, joint ventures, leveraged buyouts, spin-offs, divestitures and liquidations. ...
Evaluate the relative merits of taxable transactions versus tax-free reorganizations and spin-offs, and identify when it is best to employ one transaction over another Understand the recent significant changes to the IRS advance ruling guidelines for spin-offs, including IRS views regarding lever...