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Build Back Better Act Would Change Monetization Playbook for Tax-Free Spin-Offs

USA - January 19 2022 If enacted in its present form, the Build Back Better Act (BBBA) would amend the U.S. tax code’s rules for tax-free spin-off and split-off…

Thomas F. Wood

Build Back Better Act Would Change Monetization Playbook for Tax-Free Spin-Offs

USA - December 17 2021 If enacted in its present form, the Build Back Better Act (BBBA) would amend the U.S. tax code’s rules for tax-free spin-off and split-off…

Thomas F. Wood

Proposed Excise Tax on Stock Repurchases Has Far-Reaching Implications for Corporate Transactions

USA - November 5 2021 In legislative text released October 28, 2021, the House Rules Committee proposed to impose a 1% excise tax on stock repurchases by publicly traded…

Victor Hollender, David M. Rievman, Eric B. Sensenbrenner, Thomas F. Wood

IRS Proposes New Section 382 Regulations To Further Limit Use of Tax Losses

USA - September 27 2019 On September 9, 2019, the Treasury Department (Treasury) and the Internal Revenue Service (IRS) proposed regulations (proposed regulations) addressing…

Jared H. Binstock, Cliff Gross, Jessica A. Hough, Paul Schockett

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…

Michael J. Cardella, Stuart M. Finkelstein, Nathan W. Giesselman, Steven J. Matays, David M. Rievman