Washington, DC tax partners Michael J. Alter and Alan S. Kaden and associate W. Reid Thompson will participate in a webinar with Lorman Education Services on "Section 355: Requirements, Recent Developments, and Case Studies."
Tax-free spinoffs are a popular strategy for corporations seeking to restructure their business operations and/or dispose of corporate assets without incurring tax. Significant changes to IRS private letter ruling policy in 2013 placed more weight on opinions of tax counsel as conditions to tax-free spinoffs and raised questions about the continuing viability of certain planning techniques. Yet these changes appear to have had little effect on the popularity of tax-free spinoffs, with dozens of new public company spin-offs announced in 2014. This live webinar will review the myriad requirements of Section 355, examine historical and existing IRS private letter ruling policy and practice, and focus on issues raised by recent divisive transactions, including tax-efficient allocations of debt, cash-rich split-offs and REIT spin-offs.