After Rev. Proc. 2024-24 layered new representations and analysis onto spin-off ruling requests and the 2025 proposed regulations threatened a wholesale rewrite, Rev. Proc. 2025-30 reversed course—restoring the familiar divisive-reorganization framework and leaving practitioners to sort out what survived the round trip. This panel will trace that whipsaw and its consequences for structuring and its impact on the IRS's evolving ruling practice: the device prohibition, the active-trade-or-business requirement, de-leveraging and divisive-transaction techniques, the treatment of historical debt and its replacement or refinancing, and how those pieces resolve within the plan of reorganization.