This panel will cover recent developments regarding spinoffs, including the following topics: (1) the status of January 2025 proposed regulations, Rev. Proc. 2024-24, Notice 2024-38 and Rev. Proc. 2017-52; and (2) the status of the IRS private letter ruling program.  As part of the discussion, the panel will focus on the treatment of the following matters as a matter of law and in the IRS private letter ruling process: (1) the ability of the distributing corporation to purge boot and exchange controlled corporation debt or stock tax-free to distributing corporation creditors or shareholders, including by direct debt issuances by the distributing corporation and intermediated exchanges; (2) retentions of controlled corporation stock by the distributing corporation; (3) reborrowings by the distributing corporation after a spinoff; (4) solvency and viability concerns; and (5) reporting obligations and compliance issues.  The panel will also discuss issues regarding the device requirement and the active conduct of a trade or business requirement.