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10 Year Spin-Off Study: 1/3 Of US Spin-Offs Were Done Without An IRS Private Letter Ruling

|Includes: Altaba, Inc. (AABA), BABA

We conducted a painstaking study of 150 US publicly traded spin-offs completed over the past ten years and found that 1/3 never sought a private letter ruling from the IRS (i.e. 50 out of 150) and instead relied upon opinion of tax counsel. To our knowledge, the IRS has not come back to challenge any of those deals.

The market has been trying to interpret the meaning of the IRS 'no-rule' on the Aabaco spin-off. We hope that by sharing this information we can shed some statistical light on this subject. Lots of spin-offs proceed in the absence of a private letter ruling, and we would expect that Aabaco would be no different.

If you are interested to obtain a copy of the study please feel free to contact me.

Disclosure: I am/we are long YHOO.

Additional disclosure: The information contained herein does not constitute an offer to sell, or a solicitation of an offer to buy any security or otherwise enter into any transaction. Before making an investment decision consult with tax and legal counsel and a financial advisor to determine your suitability. This information does not purport to be complete and is no guarantee of future results. In evaluating the information, you should know that it could have been previously provided to other persons who could have already acted on it. An investor should not invest unless it is prepared to lose all or a substantial portion of its investment. Sutton View Capital LLC is organized in the United States under the laws of the State of Delaware, which laws limit the personal liability of members, including but not limited to the author.