Partner Jay M. Singer (Washington, D.C.-Tax) spoke with Tax Notes about the IRS’s letter ruling concerning spinoffs of research and development businesses that otherwise wouldn’t qualify for tax-free treatment absent a five-year track record. Jay commented that the letter ruling “moves the ball significantly” for spinoffs involving research-intensive businesses that haven’t generated income, but raises other questions about how the IRS might extend those principles. 

Read First No-Income Business Spinoff Ruling Appears Pharma-Driven