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IRS Offers Limited Safe Harbors for Recapitalizations Before Spin-Offs

USA - July 25 2016 On July 15, 2016, the Internal Revenue Service (IRS) released a new revenue procedure, Rev. Proc. 2016-40, providing safe harbors for transactions in...

Steven J. Matays, David M. Rievman, Michael J. Cardella, William Alexander, Stuart M. Finkelstein.


Proposed Treasury Regulations Raise New Hurdles for Tax-Free Spin-Offs

USA - July 20 2016 On July 14, 2016, the Internal Revenue Service (IRS) and Treasury Department proposed new Treasury regulations that, if finalized, would generally...

Steven J. Matays, David M. Rievman, Yilan Bryant, William Alexander, Stuart M. Finkelstein.


Proposed Treasury Regulations Dramatically Alter Existing DebtEquity Law

USA - April 7 2016 On April 4, 2016, the Internal Revenue Service (IRS) and Treasury Department proposed new Treasury Regulations that, if finalized, would become...

Paul W. Oosterhuis, David M. Rievman, Nathaniel Carden, Edward E. Gonzalez, David Polster.