Shearman And Sterling

Tax Bill, Supreme Court of the US, Washington DC

March 06, 2020

Jay M. Singer Quoted on Spinoffs in Tax Notes


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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

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Jay M. Singer



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