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IRS Issues Guidance on ‘North-South’ Transactions
5 May 2017
View Client Update
The IRS recently issued Revenue Ruling 2017-09 covering the treatment of so-called “North-South” transactions.
The Ruling sheds some light on when the IRS will respect the independence of transaction steps in a spin-off or reorganization, but the facts of the Ruling will not cover many transactions.
The IRS will once again provide rulings to taxpayers on North-South issues, changing a four-year “no rule” policy.
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