Revenue Ruling 2017-09: New IRC 355 North-South Spinoff Transaction Guidance and Resumption of Private Letter Rulings
Recording of a 90-minute CLE/CPE webinar with Q&A
This webinar will provide tax counsel with a critical look at recent IRS guidance on “north-south” transactions in connection with tax-free spin-offs, issued in Rev. Rul. 2017-09. The panel will discuss the facts presented in the ruling under which the IRS will respect the separate steps of a north-south transaction. The webinar will also detail continued areas of uncertainty as to whether transactions qualify for Section 355 treatment and offer strategies on when counsel should consider seeking a private letter ruling.
- Structures of north-south transactions in connection with tax-free spin-offs
- Prior IRS guidance
- Rev. Rul. 2017-09
- What type of exchange will be respected as separate transactions qualifying for non-recognition under Section 355?
- What type of exchange does Rev. Rul. 2017-09 specifically mention as likely to be integrated?
- Identifying circumstances where a private letter ruling may be appropriate prior to structuring a north-south transaction
The panel will discuss these and other important questions:
- What types of common north-south transactions in connection with tax-free spin-offs will be respected as separate? Which ones won’t?
- What types of circumstances should prompt tax counsel to seek a private letter ruling prior to a contemplated north-south transaction?
Gregory P. Broome
Wilson Sonsini Goodrich & Sonsini
Mr. Broome's practice focuses on partnership and corporate taxation matters, including significant experience in... | Read More
Mr. Broome's practice focuses on partnership and corporate taxation matters, including significant experience in mergers and acquisitions, initial public offerings, and renewable energy and project development and finance. He has spoken at several conferences on the topics of mergers and acquisitions, utility financing, and the use of partnerships and limited liability companies.Close
Devin J. Heckman
Wilson Sonsini Goodrich & Rosati
Mr. Heckman advises clients on the tax aspects of domestic and cross-border mergers and acquisitions, tax-free... | Read More
Mr. Heckman advises clients on the tax aspects of domestic and cross-border mergers and acquisitions, tax-free reorganizations, spin-offs, restructurings, financings, and joint ventures. He previously practiced at Simpson Thacher & Bartlett in New York.Close