Corporate Division and a Related Reorganization
Overview
Events that occur before or after a spin-off or a split-off can threaten their tax consequences. The step transaction doctrine, in its various forms, evaluates the tax consequences of a series of related transactions by an overall assessment rather than evaluating each transaction as though it occurred independently.1 Thus, as discussed in Chapter 4, if the shareholder sells his or her stock immediately after the spin-off, the sale is viewed as evidence that the distribution of the stock was a device to distribute earnings and profits to the shareholder. Also, a prearranged sale may result in a finding that the continuity of interest requirement is not satisfied. A post spin-off ...
Get Tax Aspects of Corporate Division now with the O’Reilly learning platform.
O’Reilly members experience books, live events, courses curated by job role, and more from O’Reilly and nearly 200 top publishers.
