The U.S. IRS has announced Revenue Procedure 2024-24, which provides updated procedures for taxpayers requesting private letter rulings from the IRS regarding certain matters pertaining to section 355 transactions. Section 355 of the Internal Revenue Code provides that if certain requirements are met, a corporation may distribute stock and securities in a controlled corporation to its shareholders and security holders without causing the distributees to recognize a gain or loss in corporate divisions commonly known as spin-offs, split-offs, and split-ups. Notice 2024-38 has also been published, requesting feedback on Revenue Procedure 2024-24. --- Revenue Procedure 2024-24 provides updated procedures for...