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:
“All history becomes subjective; in other words there is properly no history, only biography.”
—Ralph Waldo Emerson (1803–1882)
“The history of all hitherto existing society is the history of class struggles.”
—Karl Marx (1818–1883)
“In front of these sinister facts, the first lesson of history is the good of evil. Good is a good doctor, but Bad is sometimes a better.”
—Ralph Waldo Emerson (1803–1882)