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Email In a statement that would mark a stark change in approach, an IRS official recently indicated that the IRS may begin requiring that companies seeking to effect tax-free spinoffs conduct active businesses that represent a minimum percentage of the companies’ assets. The official noted that the IRS may hold future requests by taxpayers for guidance on this issue in abeyance. https://www.cadwalader.com/resources/clients-friends-memos/irs-mulls-change-to-spinoff-rules