Final regulations under section 355 of the Internal Revenue Code that would clarify the application of the device prohibition and the active business requirement of section 355. Specifically, the final regulations would provide additional guidance regarding the device prohibition of section 355(a)(1)(B) and provide a minimum threshold for the assets of one or more active trades or businesses, within the meaning of section 355(a)(1)(C) and (b), of the distributing corporation and each controlled corporation (in each case, within the meaning of section 355(a)(1)(A)). The final regulations would affect corporations that distribute the stock of controlled corporations, their shareholders, and their security holders.