Tag Archives: IRS Spinoff Guidance

Spinoff Odds & Ends: M&A For South32 , IRS To Issue Some Private Letter Rulings

It’s Thursday before Memorial Day Weekend which means it’s a perfect time for some Spinoff Odds & Ends: Thanks to Paul Singer’s Elliott Advisors there is a lot of drama swirling around BHP Billiton (BHP) (we will get to that shortly hopefully), but Bloomberg’s Gadfly checks in South32 (SOUHY), the mining giant’s 2015 spinoff. That mishmash of unloved… Read More »

IRS’ New Rules Slam Door On REIT Spinoff Loophole

Given their increased popularity and media coverage, spinoffs have recently received a lot of attention from regulatory bodies such as the IRS. In fact, one of the under reported items coming out of last year’s budget battle was Congress taking a stand against non-real estate companies spinning off REITs. Essentially, the bill requires a spinoff to wait 10… Read More »

Uncertainty To Remain As IRS Not Issuing Broad Guidance For Spinoffs Just Yet

Those hoping for the IRS to provide clear guidance on spinoff related tax issues can keep holding their breath because it’s not coming anytime soon, at least according to Robert Wellen, associate chief counsel of the U.S. tax agency. According to Mr. Wellen, these types of projects take a lot of time to complete, but on the plus… Read More »