The subsidiary does not recognize gain on the distribution of any appreciated assets to the parent, which is an exception to the general rule of Section 311(b) that treats a corporate distribution of appreciated assets as a sale.

FORBES: Tax Court Holds S Corporation Shareholders Liable for $30 Million Tax Deficiency

Strictly speaking, a spinoff is the gratis distribution of all the shares in a subsidiary to shareholders of the parent.

FORBES: A Different Spin

Persistent poverty is most acute among single-parent households: 29% of those in the bottom 30% of the income distribution in 1991 stayed there for the next five years, a higher proportion than for any other household type.

ECONOMIST: Labour��s crusade