One of the largest producers and transporters of energy in the United States

December 31, 2002

Representation of a client before the IRS in connection with an intra-group restructuring styled as an internal Section 355 spin-off. Proposed and submitted request for private letter ruling. Devised a strategy accepted by the IRS for the tax-free restructuring of company debt so as to permit a reallocation of debt in connection with the spin-off without the consent of third-party debt holders.
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