February 2021
Intermediate to advanced
156 pages
3h 37m
English
Content preview from Tax Aspects of Corporate Division
Become an O’Reilly member and get unlimited access to this title plus top books and audiobooks from O’Reilly and nearly 200 top publishers, thousands of courses curated by job role, 150+ live events each month,
Start your free trial



Examples of Section 355 Transactions
Below are examples of corporate divisions and the analyses required to determine their tax consequences. The examples are intended to serve as a review of the earlier materials.
Spin-Off Followed by B Reorganization and Loss of Control
Corporation X had been engaged in the active conduct of two businesses (toy manufacturing and hand tool manufacturing) for over 5 years. Corporation Z, an unrelated corporation, desired to acquire the stock of X but was only interested in having X conduct the hand tool manufacturing business. This was accomplished pursuant to a plan under which X transferred its toy manufacturing business to a newly created corporation, Y, in exchange for all of the stock of Y, which ...