Gaglio Interviewed by Law360 Regarding Safe Harbors Proposed by the IRS

Ryan Gaglio was interviewed by Law360 regarding safe harbors proposed by the IRS. The article discusses the IRS’ proposed new safe harbors aimed at offering certain corporate spinoffs statutory tax-free treatment. This proposal comes in the wake of previous guidance that faced criticism for its restrictive nature, and while the new rules offer more leniency, they still demand careful navigation due to the complexities inherent in each spinoff transaction. 

In the article, Gaglio emphasizes an important consideration: “There's nothing to prevent the IRS from changing the way it wants to issue PLRs, which are not part of the regulatory framework.” His insight underlines the necessity for practitioners to approach these proposed rules with caution, acknowledging that, while they provide clearer guidelines, the IRS’s interpretations may evolve, impacting their application moving forward.