active trade or business test 355</h6>

[PDF] Tax Alert - Weil, Gotshal & Manges LLP

355 1 Among other things, the Proposed Regulations require that the qualifying active trade or business (“ATB”) of both the distributing corporation a new per se device test when a distribution involves a disproportionate amount of

[PDF] The Business Purpose Test in Section 355 Distributions - CORE

continue the active conduct of a trade or business after such reorganization, or (B ) the corporation whose stock is distributed was used principally as a device for

[PDF] Recent Section 355 D lt Developments - Jones Day

Distributing Controlled Engaged in an Active Trade or Business Exceptions to the Per Se Test exist for two categories of transactions: Di id d R i dD d ti Di t ib

[PDF] New York University - Steptoe & Johnson LLP

Tax Consequences of a Section 355 Transaction the continuity of interest test, and made certain changes in the device and active trade or business tests c

[PDF] Basics of US tax-free spin-offs under section 355 - Steptoe

355, including the U S tax consequences, requirements, restrictions and potential complexities active trade or business; and (iv) distribution test However, because there is no requirement that shareholders control Distributing before or

[PDF] Proposed Regulations on Nondevice & Active Business

Rusudan Shervashidze Andrew P Mitchel Tags Active Trade or Business Test Code §355 Device Per Se Test Spinoff PROPOSED REGULATIONS ON

[PDF] Application of the Active Trade or Business Requirement under

17 juil 2019 · trade or business requirement for section 3551 distributions 2 On not intended to continue the active conduct of a trade or business after formulate and impose a test for all situations would be counterproductive, unhelpful,