Sullivan & Cromwell Discusses New IRS Ruling Policy on Spin-Off Transactions
Reynolds Holding
MAY 19, 2024
The prevalent model in the market in recent years, supported by affirmative IRS rulings, was the “direct issuance” model, under which a third party (typically a bank) would loan cash to Parent. 2017-38, 2017-22 I.R.B. 1258 (May 9, 2017) (removing such “no-rule” policy); Rev. 2013-3, 2013-1 I.R.B. 2, 2013), § 5.01(10)
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