Publications Memos Go Back The IRS Recently Announced That it Would No Longer Rule on Certain Issues in Spin-Off Transactions 06.30.03 This memo addresses the IRS's recent announcement that it will not rule on certain issues in spin-offs. Authors and Contacts Marcy Geller Partner [email protected] +1-212-455-3543 Related Insights 08.06.26 | Publications OCC Signals Heightened Focus on De Novo Charter Application Quality 08.05.26 | Publications IRS Notice 2026-36 on Section 4960 08.05.26 | Publications Debt-For-Equity Exchanges Developments – New FINRA Rule Related Services Related Practice Areas Corporate Tax Mergers and Acquisitions