Elizabeth Norman Presents ‘IRC Section 355 Corporate Spin-Off Transactions: Optimizing Tax Treatment in Divestitures’Print PDF
Elizabeth M. Norman, a partner in Nutter’s Tax Department, presented at the Strafford webinar “IRC Section 355 Corporate Spin-Off Transactions: Optimizing Tax Treatment in Divestitures” on March 30. This webinar provided tax counsel with a practical guide to the key tax considerations in structuring corporate spin-offs and carve-outs. The panel examined key legal, business, and tax considerations for deal structuring, economic terms, due diligence, and asset transfers. Panelists discussed the tax impact of various divestment transaction structures, provided best practices for minimizing transaction taxes, and explored post-divestment tax opportunities.
- Evaluating the need for pre-divestiture transactions to achieve optimal tax treatment
- Identifying and avoiding divestiture pitfalls
- Planning requirements in the absence of advance IRS guidance
- Current state of Section 355 spin-offs and split-offs
- “North-south” and “control” issues
- Anticipated Congressional/IRS action regarding REIT spin-offs