Robert Wellen Comments on Proposed Amendment to Section 361
PDFLevin's Jobs Bill Would Limit Tax-Free Receipt of Securities in a Spinoff
03.17.2010
Tax Notes Today
Ivins, Phillips & Barker partner Robert Wellen was quoted in Tax Notes Today on a proposed amendment to section 361. The amendment would treat debt securities issued by the controlled subsidy in a divisive D reorganization as taxable boot, even when used by the parent to pay its own debt or as distributions to shareholders.