14, 2015 /PRNewswire/ -- S&P Dow Jones Indices (S&P DJI) today announces a change in treatment of spin-off
transactions in the S&P U.
A sponsored spin-off
takes place when an equity stake in a subsidiary is sold to an outside investor before going public.
Previously, such so-called comfort rulings were available to resolve questions such as (i) whether a spin-off
has an adequate corporate business purpose, (ii) whether a spin-off
will be regarded as used principally as a device for the distribution of earnings and profits, and (iii) whether a spin-off
and any prior or subsequent acquisition of stock in the Parent or the Spinco are part of a plan under section 355(e).
61) analyzes 35 spin-off
organizations that arose from the Xerox Corporation.
Consequently, many taxpayers should obtain a letter ruling when contemplating a spin-off
United Communications Group (ucg) has taken a big first step in the development of its second spin-off
company in information technology (IT), American Petroleum Exchange, with the announcement due next week that through the Exchange UPS is accepting bids for 86 million gallons of fuel for its planes.
4 billion buyout of Blockbuster, has embraced the spin-off
corporations have spun off foreign subsidiaries (Fortune Brands' spin-off
of Gallaher is a notable exception), realigning multinational corporate structures has many benefits.
OTCBB:TTGL), a high-growth diversified holding company, reported that the Company's Board of Directors has authorized a definitive strategic plan to spin-off
Titan's Printed Circuit Board ("Titan PCB") manufacturing business to its shareholders, creating a new, more strategic independent public entity.
A divisive distribution (Distribution) is a spin-off
, split-off or split-up.
1) A number of related provisions and conforming amendments were adopted at the same time, the cumulative effect of which is to revise substantially the conditions for obtaining a tax-free separation -- whether as a spin-off
, split-off, or split-up(2) -- of one corporation from another pursuant to section 355.
With the spin-off
, Sears loses access to dividends from Allstate that are currently $260 million annually.