Content area
Full Text
1 PURPOSE
2: BACKGROUND
3. CHANGES
4. INFORMATION TO BE INCLUDED IN REQUESTS FOR RULINGS UNDER Sec 355 OF THE INTERNAL REVENUE CODE
.01 Information regarding Distributing and Controlled
(1) Identification
(2) Jurisdiction
(3) Taxable year
.02 Ownership of interests in Distributing and Controlled
(1) Capital structure of Distributing and Controlled immediately prior to the distribution
(2) Foreign shareholders
(3) Description of stock, securities, and other property being distributed
(a) Stock
(b) Securities
(c) Other property
(d) Timing
(e) Planned stock issuances
(f) Obtaining control
(4) Ownership of stock and securities immediately after the distribution
(a) Interests in Controlled to be held by Distributing
(i) Retention of stock, securities, or options
(ii) Retention of debt
(iii) Purpose for Distributing holding stock, securities, or options in Controlled
(b) Interests in Controlled to be held by shareholders of Distributing
(i) Distribution or exchange
(ii) Stock ownership
(iii) Securities
(iv) Surrender of stock
(c) Interests in Controlled to be held by security holders of Distributing
(d) Receipt of consideration other than with respect to stock or securities
(i) Shareholder in dual capacity
(ii) Security holder in dual capacity
(iii) Other transfers
.03 Information concerning the businesses of Distributing and Controlled
(1) Description of businesses
(2) Distributing's Active Businesses
(a) Active conduct during the preceding 5-year period
(b) Employee information
(c) Nonemployee information
(d) Continuous ownership of an Active Business during the preceding 5-year period
(e) Change in business
(f) Separation of real property, intellectual property, or other intangible property from user
(g) Balance sheets
(h) Profit and loss statements
(3) Description of Active Businesses being transferred by Distributing to Controlled
(4) Pre-existing Controlled's Active Businesses
(5) Indirect conduct of trade or business through ownership of stock in other corporations (Other Corporations)
(6) Changes in ownership of an Active Business during the preceding 5-year period
(a) Identity
(b) Dare
(c) Transaction
(d) Consideration
(e) Gain or loss
(7) Stock ownership during the preceding 5-year period
(a) Stock of Controlled or other Corporations continuously owned
(b) Stock of Controlled or other Corporations acquired
(i) Identity
(ii) Date and consideration
(iii) Transaction
(iv) Gain or loss
(c) Other changes in ownership
(8) Continuation of business
.04 Business purpose
(1) Detailed description
(2) Corporate Business Purposes
(3) Alternative transactions
(4) Cross...