Business purpose requirement for spin-offs under section 355
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Authors
Birmingham, Edward J.
Issue Date
1969
Volume
14
Issue
2
Type
Journal Article
Language
Keywords
Alternative Title
Abstract
This article deals with the subject of tax-free spin-offs in the context of family and other closely held corporations. The discussion is divided into two main sections. The first consists of a brief review of the nature of corporate divisions and the statutory scheme for their tax treatment under the Internal Revenue Code of 1954. The second section is a more detailed examination of judicial limitations on these transactions, especially the business purpose rule.
Description
Citation
Edward Birmingham, Business Purpose Requirement for Spin-Offs Under Section 355, 14 S.D. L. Rev. 250 (1969), reprinted in N.Y. B.J. (1969) and Tax L. Dig. (1969).
Publisher
License
Copyright (c) 1969 Edward J. Birmingham