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The three types of corporate divisions are commonly known as spin-offs, split-offs and split-ups. The spin-off involves a distribution of property to shareholders without the surrender of any stock, which thus resembles a dividend. The split-off resembles a redemption because the shareholders have relinquished stock of the distributing corporation.
A Reverse Morris Trust is used when a parent company has a subsidiary (sub-company) that it wants to sell in a tax-efficient manner. The parent company completes a spin-off of a subsidiary to the parent company's shareholders. Under Internal Revenue Code section 355, this could be tax-free if certain criteria are met. The former subsidiary (now ...
The sale of the relinquished property and the acquisition of the replacement property do not have to be simultaneous. A non-simultaneous exchange is sometimes called a Starker Tax Deferred Exchange, named for an investor who won a case against the Internal Revenue Service (IRS). [3]
Section 121 [50] lets an individual exclude from gross income up to $250,000 ($500,000 for a married couple filing jointly) of gains on the sale of real property if the owner owned and used it as primary residence for two of the five years before the date of sale. The two years of residency do not have to be continuous.
A corporate spin-off, also known as a spin-out, [1] or starburst or hive-off, [2] is a type of corporate action where a company "splits off" a section as a separate business or creates a second incarnation, even if the first is still active. [3]
When you contribute to a pre-tax retirement plan (such as an IRA), you can deduct those contributions from your tax return. And if you’re self-employed, you can open a Solo 401(k) plan and ...
For the 2023 tax year, those with self-only coverage can contribute up to $3,850 to an HSA, according to MoneyTalksNews, while those with family coverage have a contribution limit of $7,300.
A like-kind exchange under United States tax law, also known as a 1031 exchange, is a transaction or series of transactions that allows for the disposal of an asset and the acquisition of another replacement asset without generating a current tax liability from the sale of the first asset. A like-kind exchange can involve the exchange of one ...