IRS Encouraging Taxpayers to Discuss Section 355 Deals No-Ruling List

Taxpayers should talk to IRS if they have questions about several types of tax-free reorganizations even though IRS put them on a no-rule list in January, two agency officials say. IRS decided not to issue any more rulings on recapitalizations, leveraged spin-offs, and so-called “north-south” transactions under tax code Section 355 because it is working on three separate guidance projects addressing the deals, the officials say.


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