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in this video were going to talk about type D tax-free reorganizations so type D rear organizations can be acquisitive or they can be divisive and in this video were going to be talking about the divisive type so divisive tax theory organizations are governed not only by section 368 but also by some requirements in Section 355 which were going to talk about now there are three main types of divisive reorganizations youve got spin-offs split off and split up now Ive got another video talking about the format for each of these because you can get a little complicated so I refer you to watch that if you dont know what these are in this video Im going to give an example of a spinoff but the general rules apply to each of the three of these types so lets say that we have a corporation called treasure-hunting incorporated right so this is going to be our distributing corporation so Ill just abbreviate that D is P Corp right so its our distributing corporation they have a sharehold