By: Amanda Wilson On Monday, the IRS released Notice 2015-59. In it, the IRS announced that the IRS will no longer issue private letter rulings on whether a distribution satisfies the requirements of Section 355 for a tax-free spin-off where (i) the...

By: Amanda Wilson Yesterday, the IRS and Treasury released proposed regulations governing the treatment of certain transfers of foreign goodwill and going concern value. When a U.S. person contributes property to a foreign corporation, Section 367...

By: Amanda Wilson In their continued effort to crackdown on offshore activity, the IRS and Treasury released proposed regulations yesterday that target debt held by foreign partnerships. These regulations provide that debt held by foreign...

By: Amanda Wilson Yesterday, Senator Al Franken sent a letter to the Department of Treasury taking aim at "carried interest" income. In the letter, Senator Franken asked the IRS to revise Form 1065 (the tax return form for partnerships) to require...