If a spin-off
company is determined to be ineligible for an index, it will be removed on the first day of regular way trading using its closing price on the primary exchange.
An examination of the identities of the sponsored spin-off
blockholders reveals they are primarily sophisticated investors such as Warren Buffett, the Gabelli Fund, Morgan Stanley, and Forstmann Little.
Finally, section 355 also imposes other requirements for tax-free treatment in a spin-off
in addition to those that are subject to the new ruling policy, such as the five-year active business requirement.
United Communications Group has found a way to keep the staff of its highly successful and profitable publishing company in place as it pours millions into its two spin-off
, start-up IT companies.
will be accomplished through the pro rata dividend of 100% of Titan PCB, a wholly-owned subsidiary of Titan, to all shareholders of record on the record date set by Titan.
Under section 355(e)(2)(B), a plan is presumed to exist where (1) one or more persons, (2) acquire directly or indirectly, (3) stock representing a 50-percent or greater interest in the distributing or any controlled corporation, (4) during the four-year period beginning two years before the spin-off
The recently announced sale of Sears Tower and today's announcements of the Allstate spin-off
and plans to explore the divestiture of the Homart Development Co.
For a spin-off
to be considered nontaxable, there must be a valid corporate business purpose for the transaction and the spin-off
cannot be primarily a device for distributing earnings and profits (E&P).
Generally, the IRS will be taking a more active role in scrutinizing the motivations and purposes of the spin-off
than in the past.
45 billion in 1993, due almost entirely to the effect of the spin-off
December 19, 2006 is Date for Hathaway Shareholders to Be Eligible for Spin-off
P owns S and S owns S1), to position S1 for a spin-off
to P's shareholders, S would first have to spin S1 off to P.