Janicelynn Asamoto Park
Janicelynn Asamoto Park is an associate in the Tax Department.
Subscribe to all posts by Janicelynn Asamoto Park
On October 13, 2016, the Treasury Department and the Internal Revenue Service issued final and temporary regulations under section 385 of the Internal Revenue Code. The final and temporary regulations recharacterize certain debt instruments as equity for all federal income tax purposes. The final and temporary regulations narrow considerably the scope of the proposed regulations … Continue Reading
The U.S. Internal Revenue Service (IRS) and the Department of the Treasury (“Treasury”) have published proposed regulations that would modify the device and active trade or business requirements for tax-free spin-offs under section 355 of the Code in three important respects. First, the proposed regulations clarify the “device” test and its relationship to the “business … Continue Reading