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I am retired so I do not received any W2's. The ESPP stock (15% discount with after-tax dollars) was moved to Fidelity after I left the company (all holding periods satisfied long ago). I understand the 367(a) taxes and the ESPP taxes if they were each done standalone. But done together in the HPE/Seattle Spinco/MFGP spinoff I dont know if the ESPP rules apply since I havent really sold anything. Do I have to pay the ESPP ordinary income part now as part of the spinoff? If so, do I have to pay ordinary income part again when I actually sell the MFGP stock? Or is the ESPP part delayed and only triggered for a actual sale? I know that the MFGP cost basis gets revised as part of the 367(a) spinoff.