A divisive reorganization involves the transfer of all or part of a division, subsidiary, or corporate segment in a tax-free manner. It includes three main types: split-up, split-off, and spin-off.
A type of corporate restructuring in which a parent company divests itself of a wholly owned subsidiary by giving its shareholders the opportunity to exchange their shares for shares in the subsidiary, thereby making it an independent entity. Unlike a spin-off where shares are distributed automatically, in a split-off, the parent company makes a tender to its shareholders, who can choose whether or not to acquire shares in the new company.
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