February 13, 2013
IR Code Section 355 and "Hot Stock" Rules
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.
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).