Latest / The Acquisition Talk with Fexingo: Mergers, Buyouts, and Business Sales for Operators
How the Reverse Morris Trust Creates Tax-Free Spinoffs
In this episode of The Acquisition Talk, Lucas and Luna break down the Reverse Morris Trust — a tax-advantaged structure that lets companies spin off a division and merge it with a buyer without triggering a massive tax bill. Using the 2024 separation of GE's healthcare business as a concrete example, they walk through the mechanics, the 50 percent ownership rule, and the IRS conditions that make this structure so powerful but so rare. They also explore why the Reverse Morris Trust fell out of favor in 2025 and 2026, as buyers and sellers shifted toward taxable deals that closed faster…
The skinny
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