IRS PLR: S Corporation Spin-Off Qualifies as Tax-Free Reorganization (IRC §368)

The IRS has published a private letter ruling on I.R.C. §368 and §355, confirming a tax-free reorganization where an S corporation can contribute business assets to a newly formed controlled corporation, and distribute its stock to shareholders, without recognizing gain or loss on the contribution. [PLR 202551007]

This story was produced by Bloomberg Tax Automation, and edited by Bloomberg Tax staff.