Details

This course focuses on corporate spin-offs and other transactions designed to qualify for tax-free treatment under section 355 of the Internal Revenue Code, including: in-depth consideration of statutory and regulatory requirements; impact of pre- and post-spin transactions; IRS ruling procedures and policies; roles of outside tax counsel; and examination of actual public company transactions. Students will participate in the drafting of ruling requests, opinion letters, and other documentation associated with such transactions. Final Examination Pre-requisite: Corporate Taxation. Not open to second year JD students who are not enrolled in the Joint Degree Program without the permission of the instructor. Basic Federal Income Tax is a pre-requisite for JD candidates.