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:
“In the history of the United States, there is no continuity at all. You can cut through it anywhere and nothing on this side of the cut has anything to do with anything on the other side.”
—Henry Brooks Adams (1838–1918)
“Don’t you realize that this is a new empire? Why, folks, there’s never been anything like this since creation. Creation, huh, that took six days, this was done in one. History made in an hour. Why it’s a miracle out of the Old Testament!”
—Howard Estabrook (1884–1978)
“To care for the quarrels of the past, to identify oneself passionately with a cause that became, politically speaking, a losing cause with the birth of the modern world, is to experience a kind of straining against reality, a rebellious nonconformity that, again, is rare in America, where children are instructed in the virtues of the system they live under, as though history had achieved a happy ending in American civics.”
—Mary McCarthy (1912–1989)