§ 355

Rev. Rul. 68-603: Acquiescence to Morris Trust; see § 355(e)

Rev. Rul. 57-114: Failed spin; distribution on newly issued stock

Rev. Rul. 2001-29: Rental activity producing rent under § 856(d) can be an ATB

Rev. Rul. 2019-9: Collection of income; § 355

Rev. Rul. 57-311: Cross-chain transfer treated as a split-off

Rev. Rul. 70-434: Spin of unwanted business followed by B reorg with acquiror; pre-§355(e)

Rev. Rul. 79-394: Reimbursement for employees of related corp

Rev. Rul. 2003-79: Sub-all transferred in C reorg of spun Controlled

Rev. Rul. 79-258: § 357(b) does not apply to substitution of debt

Rev. Rul. 77-191: Indirect spin treated as D/355

Rev. Rul. 78-251: No device where SHs elect cash in lieu of stock

Rev. Rul. 2003-18: Franchise addition treated as expansion of ATB

Rev. Rul. 69-407: Recapitalization into control for spin-off

Rev. Rul. 62-138: § 351(c) applied in context of § 355 spin-offs

Rev. Rul. 83-142: Interim steps to comply local law are disregarded

Rev. Rul. 70-18: Inter-group reorganization satisfies § 355 control

Rev. Rul. 2003-38: Good § 355 spin-off of Internet sales business - Expansion

Rev. Rul. 74-79: ATB requirement met before spin; pre-§355(b)(3)

Rev. Rul. 78-442: Qualifying ATB though gain recognized under § 357(c)

Rev. Rul. 98-27: Control satisfied despite post-distribution reorg

Rev. Rul. 2003-55: Good § 355 spin even though IPO not completed

Rev. Rul. 2002-49, Situation 2: 5-year ATB requirement failed

Rev. Rul. 2002-49, Situation 1: 5-year ATB requirement met; expansion

Rev. Rul. 92-17: ATB requirement met through a partnership

Rev. Rul. 63-260: Failed spin due to transitory control

Rev. Rul. 57-144: Disqualified spin-off; control not met

Rev. Rul. 2007-42: ATB through a partnership

Rev. Rul. 2017-9, Sit. 2: North-South Ruling - Distribution pursuant to a plan

Rev. Rul. 2017-9, Sit. 1: North-South Ruling - Transfers treated as separate

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