Was the Spin-Off of PayPal from eBay a Taxable or a Tax-Free Reorganization?

Journal of Case Research and Inquiry

25 Pages Posted: 22 May 2024

See all articles by Gretchen lawrie

Gretchen lawrie

California State University

John R. Cooper

California State University

Date Written: April 9, 2024

Abstract

This case study reviews the facts of eBay, Inc.’s spin-off of PayPal, Inc., which presents an opportunity to reinforce the student’s understanding of the complex US corporate reorganization provisions. The case study leads to the question: What would have been the US tax and non-tax consequences of eBay’s spin-off of PayPal for eBay, PayPal, and eBay’s shareholders?

Keywords: PayPal, eBay, corporate reorganization, tax-deferred and taxable reorganizations, tax planning

JEL Classification: K34 Tax Law

Suggested Citation

lawrie, Gretchen and Cooper, John R., Was the Spin-Off of PayPal from eBay a Taxable or a Tax-Free Reorganization? (April 9, 2024). Journal of Case Research and Inquiry, Available at SSRN: https://ssrn.com/abstract=4789064 or http://dx.doi.org/10.2139/ssrn.4789064

Gretchen Lawrie (Contact Author)

California State University ( email )

John R. Cooper

California State University

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