Clifford Chance
New Spin-off Rules
21 July 2016
On July 14 and 15, 2016, the Treasury and the IRS issued new guidance on the requirements for tax-free corporate "spin-off" transactions. The guidance includes proposed regulations which would make it more difficult to successfully execute a tax-free spin-off transaction, when the distributing company and/or the distributed company holds significant nonbusiness assets.
