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IRS Issues Guidance on “North-South” Transactions

By Richard M. Corn, Bowon Koh & David S. Miller on May 16, 2017

On May 3, the Internal Revenue Service (the IRS) issued Revenue Ruling 2017-09 (the “Ruling”), which helpfully clarifies that the separate steps of a typical “north-south” spinoff transaction will be respected, and announced that it would once again issue private letter rulings on north-south transactions.

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