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Email Richard Nugent comments on recent IRS guidance creating safe harbors for corporations that want to engage in tax-free spinoffs but have trouble satisfying the control requirement, providing that a recapitalization into control by way of a dual voting structure can be unwound two years after the spinoff without threatening the tax-free nature of the spin. https://www.cadwalader.com/news/recent-press/guidelines-placed-on-control-workarounds-for-spinoffs