Partner Jay Singer spoke at PLI’s Tax Strategies for Corporate Acquisitions, Dispositions, Spin-Offs, Joint Ventures, Financings, Reorganizations & Restructurings 2021 conference in Los Angeles, California. His discussion was titled “Current Issues in Divisive Strategies – Spin-Offs,” and he spoke about:

• tax-free spin-offs, split-offs and split-ups under Section 355
• analysis of issues in innovative divisive transactions
• developing IRS/Treasury views on no-rule policy
• changes in administrative practice; evolving techniques for leveraged distributions
• unresolved interpretive issues under Sections 355(d) and (e); cash-rich split-offs; restructuring issues for spin-offs
• issues and techniques arising from the enactment of the 2017 Tax Act