New Section 355 No-Rule Policies
Skadden
February 13, 2013
5 pages
IR Code Section 355 and "Hot Stock" Rules
World’s Longest Letter Ruling Alston + Bird
November 1, 2012
2 pages
Flexibility Created for Pre-Spin-Off Taxable Corporate Acquisitions
SNR Denton
November 2, 2011
Tax-Free Spin-Offs: The Internal Revenue Service Finalizes “Hot Stock” Rules Without Change
Sullivan & Cromwell
October 20, 2011
The Section 355(d) Regulations: Narrowing the Scope of an Overly Broad Statute
Steptoe & Johnson
October 18, 2011
New Avenue for IRS to Issue Rulings on Select Issues in Section 355 Spin-Offs
Pepper Hamilton
June 9, 2009
Please see our Hot Topics for more on this subject.
Spin-Offs Become Easier and Easier
Alston +
Bird
Federal
Tax Advisory
February 2,
2009
Tax-Free Spin-Offs: The Internal
Revenue Service Issues Temporary Regulations Liberalizing the “Hot Stock” Rules
Sullivan
& Cromwell
December
23, 2008
This Alert
reviews temporary regulations from the IRS that limit the application of its “hot
stock” rules in Internal Revenue Code Section 355 spin-offs and which will result in
tax-free treatment for certain subsequent distributions of stock that would
have otherwise been taxable if distributed within five years of the initial distribution.
IRS Issues Temporary Regulations
Suspending the Application of the “Hot Stock” Rule in Certain Tax-Free
Corporate Spin-Offs
Latham
& Watkins
December 17,
2008
This Alert
reviews new IRS regulations that harmonize the 2007 Active Business Test and
the “hot stock” rule so that the benefits of the newly enacted 2007 Active
Business Test for companies looking to spin-off of business units on a tax-free
basis are not lost as a result of the “hot stock” rule (which provides that stock of a spun-off entity that is acquired by the
distributing corporation in a taxable transaction within five years of the initial
distribution is taxable).
