SAN DIEGO-Qualcomm Inc. announced it is delaying the initial public offering of Spinco common stock until January due to unfavorable market conditions.
The Internal Revenue Service ruled that Qualcomm Inc.’s proposed spinoff of Qualcomm Spinco, its integrated circuits and system software business, should be a tax-free distribution to Qualcomm and its stockholders, provided that the spinoff is executed in accordance with the representation made in the ruling request.
The decision would allow Qualcomm stockholders to receive shares of Spinco common stock and cash payments for fractional shares. Cash payments in lieu of fractional shares would be taxed for U.S. federal income tax purposes.
