June 28, 2013

IRS Announces No More Rule Rulings on Spin-Offs & Reorgs

A few days ago, the IRS issued Revenue Procedure 2013-32 to announce a new “no-rules” policy that impacts spin-offs and reorganization. Effective for ruling requests received after August 23rd, the IRS will no longer rule on whether a transaction qualifies for nonrecognition treatment under sections 332, 351, 355, 368 and 1036 of the Internal Revenue Code in an effort to conserve resources. Instead, the IRS will rule only on “significant issues” arising under these provisions. Learn more in the memos posted in our “Tax” Practice Area.