If I understand correctly, companies used to be able to spin off large amounts of shares tax free by bundling them with tiny segments of their business. The IRS used to let companies ask "did we do this right?" but this time instead of saying "yes" or "no" they said "we won't answer questions like this any more and we want to rethink our rules" which is still in progress.

So if the above is roughly accurate it's more like the loophole everybody used is closing and now they're going with a less desirable loophole.