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Business purpose requirement for spin-offs under section 355
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).
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 ...