History
The original Morris Trust structure was the result of a favorable ruling in IRS v. Morris Trust in 1966. The original Morris Trust structure is similar to the above Reverse Morris Trust structure, however instead of a former subsidiary merging with a target company, the parent company would merge with target company.
Following several leveraged Morris Trust transactions similar to the original Morris Trust transaction, but involving cash and bank loans rather than mere stock, Congress enacted Internal Revenue Code Section 355(e) in 1997. This imposes additional taxation on the distribution in the spin-off step whenever 50% interest in a spun off company is transferred tax-free in the two years following a spin-off.
Read more about this topic: Reverse Morris Trust
Famous quotes containing the word history:
“When we of the so-called better classes are scared as men were never scared in history at material ugliness and hardship; when we put off marriage until our house can be artistic, and quake at the thought of having a child without a bank-account and doomed to manual labor, it is time for thinking men to protest against so unmanly and irreligious a state of opinion.”
—William James (1842–1910)
“In history an additional result is commonly produced by human actions beyond that which they aim at and obtain—that which they immediately recognize and desire. They gratify their own interest; but something further is thereby accomplished, latent in the actions in question, though not present to their consciousness, and not included in their design.”
—Georg Wilhelm Friedrich Hegel (1770–1831)
“We have need of history in its entirety, not to fall back into it, but to see if we can escape from it.”
—José Ortega Y Gasset (1883–1955)