Investments in private companies by way of share purchases from existing shareholders (secondary transactions) raise a unique set of complexities, which are often overlooked. Share issuances in company-led financing rounds...more
On September 14, 2015, the Internal Revenue Service (“IRS”) issued Notice 2015-59 (the “Notice”) and Revenue Procedure 2015-43 (the “Rev Proc”; together with the Notice, the “Spin-Off Guidance”). Under the Spin-Off Guidance,...more
9/18/2015
/ Corporate Taxes ,
Distribution Rules ,
IRS ,
New Guidance ,
Private Letter Rulings ,
REIT ,
Revenue Procedures ,
RICs ,
Shareholders ,
Spinoffs ,
Tax-Free Transfers