IRS Comments on North/South Ruling and Current Ruling Posture for Section 355 Transactions

The Practical Tax Lawyer

Summer 2017

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