Overview
Steptoe partners Robert Rizzi and Lisa Zarlenga and associate Lauren Azebu authored an article titled "A New Role for the Device Test?" published March 22 in Tax Notes. The article examines the role of the no-device requirement, discusses the limited options available to the IRS and Treasury to address their concerns about General Utilities repeal, and reviews the state of spinoff planning following the release of Rev. Proc. 2015-43 and Notice 2015-59 that brought increased uncertainty to the planning of spinoff transactions.
