IRC 355 FULL
IRC 355 SERIES
IRC 355 FREE

IRC 355 SERIES

This article is one of a series of blog posts addressing planning issues relating to qualified small business stock (QSBS) and the workings of Sections 12 of the Code.

IRC 355 FREE

We have been serving the legalДЄnd accounting community for over 30 years.Navigating through recapitalizations, reorganizations, stock splits, reverse stock splits, tax free exchanges, tax-free divisions, and stock distributions involving Section 1202 Qualified Small Business Stock (QSBS)

Strafford's live courses offer you a high quality andД¬onvenient Continuing Legal Education and Continuing Saleem Moghal Paul Hastings Janofsky & Walker Want to see more? The subject matter was very timely and informative. The teleconference addressed a highly relevant topic that recurs in my practice. StraffordвЂ™s program provided useful planning tips. Strafford webinars are convenient and offer timely topics with knowledgeable presenters. Peter Stathopoulos Managing Director, State and Local Tax Practice Bennett ThrasherД®ric Tresh Partner & Co-Chair, State & Local Tax Practice Sutherland Asbill & BrennanДЄmanda Wilson Shareholder Lowndes Drosdick Doster Kantor & Reed Customer Reviews Susan Seabrook Partner Eversheds Sutherland Todd Reinstein Partner, Corporate Tax and Due Diligence Pepper Hamilton Suzanne Ross McDowell Partner, Tax-Exempt Organizations Steptoe & Johnson Mandarino Partner Smith Gambrell & Russell Leigh Griffith Partner and Practice Group Leader - Tax Waller Lansden Dortch & Davis Lynn Fowler Partner Kilpatrick Townsend & StocktonД®dward Froelich Of Counsel Morrison & FoersterДaniel L. Janice Eiseman Principal Cummings & Lockwood Patrick Derdenger Tax Partner Lewis Roca Rothgerber Christie Byrnes Associate Dean, Special Projects Texas A&M University Law Barnett Partner Capell Barnett Matalon & Schoenfeld

IRC 355 FULL

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This 90-minute webinar is eligible in most states for 1.5 CLE credits and accredited for 1.5 CPE credits.

What types of circumstances should prompt tax counsel to seek a private letter ruling prior to a contemplated north-south transaction?.

What types of common north-south transactions in connection with tax-free spin-offs will be respected as separate? Which ones wonвЂ™t?.

The panel will discuss these and other important questions:

Identifying circumstances where a private letter ruling may be appropriate prior to structuring a north-south transaction.

2017-09 specifically mention as likely to be integrated?

What type of exchange will be respected as separate transactions qualifying for non-recognition under Section 355?.

Structures of north-south transactions in connection with tax-free spin-offs.

Listen as our experienced panel discusses the impact of the new IRS guidance on north-south transaction structures, including strategies on when to pursue private letter rulings in advance of contemplated transactions. Failure to comply with these complex rules could result in a significant tax cost. The guidance, however, is limited and does not cover all types of contemplated spinoffs. The recent revenue ruling presents fact-pattern examples of when a north-south transaction will, and will not, qualify for tax-deferral treatment, and announces that the IRS will resume issuing PLRs, since these spinoff transactions are no longer on their list of issues under study. Complicating matters for tax counsel, since 2013 the IRS has not issued private letter rulings for any north-south spinoff transaction. However, the IRS has long reserved the right to integrate the contribution and distribution. The transactions are often structured with the intent of non-recognition treatment as a corporate spinoff under IRC 355 or with the intent of a nontaxable intercompany distribution under IRC 301. This ruling reversed the IRSвЂ™s previously announced course, specifying that the IRS would resume issuing private letter rulings on whether these вЂњnorth-southвЂќ transactions would be integrated or respected as separate for federal income tax purposes.ДЄ north-south transaction involves both the contribution of assets to and the distribution of assets from a corporation pursuant to the same overall plan. 2017-09, offering guidance in the federal tax treatment of certain вЂњnorth-southвЂќ transactions in connection with tax-free spin-offs.

Irc 355