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Was the Patriot Coal spin-off tax free for foreign shareholders?

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Was the Patriot Coal spin-off tax free for foreign shareholders?

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Certain non-U.S. jurisdictions may choose to subject this type of corporate reorganization to taxation even though the distribution of Patriot Coal common shares is not taxable under U.S. Federal law. You should consult your own tax advisor regarding the particular consequences of the spin-off to you, including the applicability and effect of any U.S. federal, state, local and foreign tax laws.

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