Mark J. Silverman & Lisa M. Zarlenga (both of Steptoe & Johnson, Washington, D.C.) have published Anti-Morris Trust Plan Regulations:  The Final Chapter in the Saga, 110 Tax Notes 967 (Feb. 27, 2006), also available on the Tax Analysts web site as Doc 2006-3124, 2006 TNT 39-39.  Here is the abstract:

The IRS and Treasury recently issued final plan regulations under § 355(e), which represent the final chapter in a saga that has been evolving since the issuance of the initial proposed regulations in 1999. The authors believe the final regulations retain the reasonable, bilateral approach of the 2002 temporary regulations and provide additional helpful guidance in the context of pre- distribution acquisitions and public offerings. This article explores the latest guidance and considers whether it goes far enough.