Tax Aspects of Corporate Division

Index

Acquisition of control, 77–99

“not acquired by purchase,” 84–85

purchase of stock, 83

purchase, spin, and sell technique, 77–81

section 355(d). See Section 355(d)

statutory solution, 82–83

Active conduct, 27–30, 60–61

Active trade or business requirement, 60–61

Affiliated group, 30, 94–95, 112–113

Aggregation rules, 90, 92

Anti-avoidance rule, 97–98

Assets, nature and use of, 50–51

Attribution rules, 90, 92, 94, 95, 96, 99

B reorganization, 85, 91, 121–122

Badanes v. Commissioner, 41, 43

Balancing of factors, examples of, 52–56

Board of Tax Appeals, 14–15

“Born-to-die” ruling. See Revenue Ruling 2003-79

Brother-sister corporations, 115

Brother–sister split-off, 128–130

Business

acquisition of control, 77–99

active conduct of, 27–30, 60 ...