What Updated PLR Procedure May Mean For Stock Spin-Offs

By Michael Cardella, Nathan Giesselman and Thomas Wood (May 29, 2024, 5:48 PM EDT) -- On May 1, the U.S. Department of the Treasury and the Internal Revenue Service released Revenue Procedure 2024-24, which sets out substantially revised guidelines for private letter ruling, or PLR, requests regarding tax-free spinoff and split-off transactions, and related debt reallocation transactions....

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