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You are here: Area of Law Tax Corporate Tax: Regulation & Guidance IR Code Section 355 and "Hot Stock" Rules

IR Code Section 355 and "Hot Stock" Rules

SkaddenLogoNew Section 355 No-Rule Policies

Skadden
February 13, 2013
5 pages

AlstonBirdLogoWorld’s Longest Letter Ruling

Alston + Bird
November 1, 2012
2 pages

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

Please see our Hot Topics for more on this subject.
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.

Please see our Hot Topics for more on this subject.
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).

Please see our Hot Topics for more on this subject.