So clearly we are in a “carve out” scenario.

So clearly we are in a “carve out” scenario.

Carve-Out
In a carve-out, the parent company sells some or all of the shares in its subsidiary to the public through an initial public offering (IPO).

Unlike a spin-off, the parent company generally receives a cash inflow through a carve-out.

Since shares are sold to the public, a carve-out also establishes a net set of shareholders in the subsidiary. A carve-out often precedes the full spin-off of the subsidiary to the parent company's shareholders. In order for such a future spin-off to be tax free, it has to satisfy the 80 percent control requirement, which means that not more than 20 percent of the subsidiary's stock can be offered in an IPO.