Spin-off shares are not considered a dividend. The

Spin-off shares are not considered a dividend. They are a recapitalization of the company's share structure and will be subject to capital gains or losses when sold.

See my earlier post for move details. This fully explains the tax treatment and the new cost basis of the parent company and spin-off company shares.

http://investorshangout.com/post/view?id=1861721