Certain U.S. Federal Income Tax Consequences of the Spin-Off:
The Spin-Off is taxable to the recipient, as with any dividend. It is referred to as a dividend in other places also. The "Special" part is the SEC rules. People that owned on the record date will be sent the shares, but with a bill (for the shares) from the folks that bought between the record date to the distribution date. One good thing is they will not have to pay taxes on it. You can believe what ever you want. I did enjoy the discussion though
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