A spin-off of assets or stock by a corporation can incur significant corporate and stockholder-level tax if not properly structured. There are numerous and often esoteric requirements for a spin-off to qualify as a tax-free transaction for U.S. federal income tax purposes.

This presentation will help tax advisors and in-house tax practitioners understand the reasons when to pursue a tax-free spin-off, the requirements of a tax-free spin-off and common pitfalls in tax-free spinoff structuring.

This workshop will also discuss areas under current IRS study, recent revisions to the IRS private letter ruling policy, and alternative structures if a tax-free spin-off is not available.

Finally, this discussion will discuss issues specifically impacting technology and life science companies.What You'll Learn:When Does a Tax-Free Spinoff Make Sense?

• Costs Versus Value
  
• Operational Restrictions
  
• Availability for Technology Companies

Basic Requirements and Structures

• Statutory and Regulatory Requirements
  
• Core Documents
  
• Spin-off Structures

IRS Study and Rulings

• Recent IRS Guidance and Regulations
  
• Revisions to Private Letter Ruling Request Requirements and Ruling Policy

Alternatives

• Tracking Stock
  
• 336(E) Elections