While the deal raises some compelling questions about the US tax regime, for this site, the interesting thing about Covidien is that it has the unique distinction of being both a spinoff AND a parent company. The company came about back in 2007 when spinoff machine Tyco (TYC) unloaded its healthcare business. After a few years of independence, the company increasingly found itself focused on its medical devices business so it decided to spin off its pharmaceuticals business, Mallinckrodt (MNK). MNK has been on an absolute tear since being spun off last year and this deal means COV holders will also make out quite well. Another spinoff win and this situation now rests in the hands of merger arb specialists.
Disclosure: Author holds no position in any stock mentioned.