Jay M. Singer
By McDermott Will & Emery, Jay M. Singer and Timothy S. Shuman on Apr 11, 2018
Posted In Tax Reform, Uncategorized
Partners Alexander Lee, Tim Shuman, Britt Haxton and Jay Singer discuss novel concerns facing CFCs in light of tax reform.
IRS Issues Safe Harbors under Which the IRS Will Not Assert That a Corporation Lacks the Requisite ‘Control’ for Purposes of Section 355(a)
By Jay M. Singer on Jul 18, 2016
Posted In IRS Guidance, Uncategorized
On July 15, 2016, the Internal Revenue Service (IRS) released Rev. Proc. 2016-40. This revenue procedure provides safe harbors in which the IRS will not assert that a distributing corporation, D, lacks control of another corporation, C, within the meaning of Code section 355(a)(1)(A) when D acquires putative control of C through C’s issuance of stock and...