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.

Section 355 allows a corporation with one or more businesses that have been actively conducted for five years or more to make a tax-free distribution of the

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