Daily Tax Update - November 10, 2015: Darden Receives PLR, Completes Spinoff

Darden Receives PLR, Completes Spinoff:  Darden Restaurants, Inc. (Darden) announced yesterday that it completed its spin-off of select real estate and restaurant assets into Four Corners Property Trust, Inc. (FCPT), and that it had received a private letter ruling from the IRS on certain issues relevant to the qualification of the spin-off as tax-free.  FCPT intends to elect and qualify to be treated as a real estate investment trust effective January 1, 2016.  For prior DTU coverage of IRS guidance in this area click here.