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Email Richard Nugent comments on Robert Wellen's recent explanation of the thinking behind the new so-called hot dog stand regs addressing the active trade or business, device, and business purpose requirements for tax-free spinoffs and the new safe harbor for taxpayers seeking to unwind a recapitalization into control. Wellen is IRS associate chief counsel (corporate). https://www.cadwalader.com/news/recent-press/size-does-matter-wellen-explains-new-hot-dog-stand-regs