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 Tomorrow I will be participating in a webinar dealing with Section 704 - partnership allocations. If you are interested in attending, more information can be found here: