February 2021
Intermediate to advanced
156 pages
3h 37m
English
Content preview from Tax Aspects of Corporate Division
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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 ...