IRS Comments on North/South Ruling and Current Ruling Posture for Section 355 Transactions
The Practical Tax Lawyer
In this article, David Zimmerman, Layla Asali, Andrew Howlett, and Daniel Barron* discuss Internal Revenue Service (IRS) guidance on north/south transactions and debt issuances in the context of spin-offs and summarize recent comments from the IRS with respect to the guidance.
*Former Miller & Chevalier attorney