雅虎将继续剥离阿里巴巴股份

Yahoo said on Monday that it will push ahead with the spin-off of its stake in Alibaba, theChinese ecommerce company, by the end of the year, despite signs that US authorities areunhappy about allowing such deals to take place without incurring a tax charge.

周一雅虎(Yahoo)表示，将继续推动在年底前剥离其手中持有的阿里巴巴(Alibaba)股份——尽管有迹象表明美国当局并不愿允许公司不缴纳税款就开展这类交易。阿里巴巴是一家中国电子商务公司。

The disclosure that the spin-off would go ahead, subject only to an opinion from thecompany’s tax advisers, sent Yahoo shares up by more than 3 per cent in after-market trading,erasing part of the 5.25 per cent loss they had suffered during normal trading on Monday.

根据这一爆料，雅虎将只遵照该公司税务顾问的看法，继续开展剥离交易。消息传来，雅虎股价在盘后交易中上涨逾3%，令周一交易日期间5.25%的亏损幅度收窄了一部分。

Doubts about the fate of Yahoo’s long-planned disposal of its Alibaba stake, currently worthsome $22bn, were heightened earlier this month when it revealed that the Internal RevenueService had declined to issue a letter in advance of the deal confirming that it would be tax-free. The IRS did not indicate which way it would rule, leaving a question over a deal that iscentral to the $27bn value of Yahoo itself.

本月早些时候，对于雅虎规划已久的阿里巴巴股份处置方案的命运，人们的怀疑大大增加。当时，该公司披露美国国税局(Internal Revenue Service，IRS)拒绝在交易前发出信件，确认此次交易将不会被课税。IRS并未明示将如何裁决，从而为该交易留下了一个问号。对于雅虎270亿美元的市值来说，这次剥离交易是一个核心问题。

The IRS went on to issue a public notice this month that it was “concerned about deals thatfit the pattern that Yahoo was planning and was considering issuing new guidance on suchdeals. US companies have been able to spin off significant shareholdings and other assets freeof tax provided they place them in a new company along with ongoing operations.

接着，IRS曾在这个月发布一份公告，表示十分“关切那些与雅虎计划中交易的模式相符的交易，并且在考虑为此类交易发布新的规定。此前，美国企业一直可以将所持有的大量股权及其他资产剥离而不必缴纳税金，条件是它们将这些资产和正在运营的业务一道注入一家新成立公司。

However, the IRS also signalled that any change in its guidance about the tax status of spin-offs would not apply retroactively, easing some of the worries among Yahoo investors.

不过，IRS也曾表示，对剥离交易税务状况规定的任何变更，都不会溯及既往。这一表态在一定程度上减轻了雅虎投资者的担忧。

The mixed signals from US tax authorities left Yahoo facing a number of options, none of whichwould has been as good for shareholders as a clean, tax-free spin-off.

美国税务当局释放的种种矛盾信号，令雅虎面临一系列选择。对股东来说，所有选项都比不上干净而无需缴税的剥离交易。

It said on Monday it would continue with the original plan even in the absence of confirmationfrom the IRS, as long as it received a legal opinion about the tax-free nature of the deal, withthe transaction due to take place in the final quarter of this year.

周一，雅虎表示即便没有IRS的确认，该公司也会在了解有关该交易是否免税的法律意见后，继续按照最初计划执行，交易定于在今年最后一季度开展。