Certain Issues Relating to Debt Reallocations in Connection with Divisive Reorganizations Reflected in Rev. Proc. 2024 24 and Notice 2024 38

SIFMA provided comments to the Internal Revenue Service (IRS) on certain aspects of the recently issued Rev. Proc. 2024-24 and the associated Notice 2024-38 (the "Notice"), relating to IRS standards for issuing private letter rulings under Section 361 in connection with so-called debt-for-debt and debt-for equity exchanges, as well as leveraged distributions, in each case in connection with divisive reorganizations under Sections 368(a)(1)(D) and 355.