See Credit Details Below
Overview
Why You Should Attend
On May 1, 2024 the IRS and Treasury released Rev. Proc. 2024-24 and Notice 2024-38, modifying the IRS ruling positions for seeking a private letter ruling and foreshadowing published guidance on a variety of significant issues and components of spin-off transactions.
For tax practitioners seeking a deeper understanding of Rev. Proc. 2024-24 and Notice 2024-38, PLI is delighted to present this new half-day program in which leading experts, including representatives from the IRS and Treasury, will review this guidance and discuss the implications for successfully executing spin-offs moving forward.
What You Will Learn
After completing this program, participants will be able to:
- Gain important insight into Rev. Proc. 2024-24 and Notice 2024-38 and the government’s thinking behind the guidance
- Understand the government’s framework for retained equity and debt allocations
- Identify the possible types of creditors and liabilities and the operation of the Treasury function in a large public company
- Dissect the mechanics for debt-for-equity exchanges and the commercial and legal considerations
- Explore the rationale for considerations related to post-spin payments and continuing relationships
- Review the device limitation and Section 355(e) draft representations
Who Should Attend
This program is designed for corporate tax managers, tax attorneys, accountants and anyone interested in exploring the impact of Rev. Proc. 2024-24 and Notice 2024-38 on spin-off transactions.
Program Level: Overview
Intended Audience: Attorneys at law and accounting firms, in-house tax counsel and other tax professionals seeking to understand the recent IRS and Treasury guidance related to spin-offs.
Prerequisites: Interest in exploring the impact of Rev. Proc. 2024-24 and Notice 2024-38 on spin-off transactions.
Advanced Preparation: None