Overview
Tax Notes Federal quoted Eric Solomon in a January 3, 2022 article titled "Seeking a Holistic Guide For Spinoff Letter Rulings." The piece highlights the reasons behind tax professionals' desire for updated IRS guidance on obtaining letter rulings regarding spinoff transactions.
To be treated as tax-free, taxpayers need assurance that their spinoff transactions adhere to the requirements of section 355. Stressing the importance of letter rulings in providing this assurance, Solomon states that, "The only true insurance policy is a ruling from the IRS…The harder the issue is, the more likely the taxpayer is going to want to go to the IRS and ask for a ruling on the issue."
The full article can be read at Tax Notes Federal (subscription required).