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On September 25, 2018, the IRS announced that it is considering guidance on the treatment of spinoffs involving business ventures engaged in research and development for future profit. The announcement is of special interest to life sciences and other technology ventures actively engaged in R&D for new pharmaceutical, medical device or other technology-based products. In particular, the announcement addresses situations where a company seeks to spin off a historic R&D-based business before its intellectual property has been fully developed or commercialized.Click here to read the full alert.

Disputing Tax has monitored this and related topics closely and has previously reported on this LB&I campaign here.