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Internal Revenue Service Alters Its View on Section 355 Spin-Offs

The Internal Revenue Service ("IRS") recently issued important guidance identifying new positions the IRS is considering on critical aspects of tax-free spin-offs, and significantly expanding the information that taxpayers...more

IRS Updates Fast-Track Program for Certain Corporate Tax Rulings

A new program offers rulings in 12 weeks, even absent a showing of business need. Revenue Procedure 2023-26, issued July 26, 2023, in replacement of a popular 18-month pilot program under Revenue Procedure 2022-10,...more

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