Layla Asali addressed new regulations addressing the treatment of predecessors and successors for purposes of requiring gain recognition in spinoffs under section 355(e) and other recent corporate tax developments. In her presentation at the American Bar Association (ABA) Section of Taxation meeting on January 21, Asali observed an apparent change in the Internal Revenue Service's (IRS's) private letter ruling policy on "significant issues" and asked an IRS official whether the IRS intended to narrow the scope of issues that it will rule.

Ms. Asali's remarks were also included in the January 30 Tax Analysts article, "Practitioners Question Predecessor Rule in Spinoff Regs."​