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Clifford Chance

Briefings

New Spin-off Rules

21 July 2016

On July 14 and 15, 2016, the Treasury and the IRS issued new guidance on the requirements for tax-free corporate "spin-off" transactions. The guidance includes proposed regulations which would make it more difficult to successfully execute a tax-free spin-off transaction, when the distributing company and/or the distributed company holds significant nonbusiness assets.


 

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New Spin-off Rules

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