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Updated Interest Deductibility Guidance Released by the IRS under Section 163(j)

USA - August 28 2020 On July 28, 2020, the Treasury Department and the IRS issued final and proposed regulations (the "Final Regulations" and "New Proposed Regulations")…

Brian Harris, Kat Saunders Gregor, Leo P. Arnaboldi III, Lucas Caruso, Sara Clevering.

IRS Suspends Prior Guidance Limiting Tax-Free Spinoffs

USA - April 3 2019 On March 21, 2019, the IRS announced it is temporarily suspending two revenue rulings addressing tax-free spinoffs. The suspended rulings had…

Benjamin Rogers, David H. Saltzman.

IRS Considers Giving More Ventures Access to Tax-Free Spinoffs

USA - October 2 2018 On September 25, 2018, the IRS announced that it is considering guidance on the treatment of spinoffs involving business ventures engaged in research…

Benjamin Rogers, David H. Saltzman.