If a warrant to acquire stock in the distributing corporation is acquired in a dividend distribution, taxation to the recipient-shareholder depends on whether the dividend is taxable or not (
see Q 
7509). If it is a nontaxable stock dividend, there is no immediate income taxation. 
See Q 
7511 to determine the tax basis of a warrant acquired in a nontaxable stock dividend. If the dividend is taxable, it is treated as a dividend “in kind,” so that the amount that generally must be included in the recipient-shareholder’s income is the fair market value of the warrant on the date of distribution.
1 This is also the warrant’s tax basis (
see Q 
7503).
  If a corporation distributes a warrant to acquire stock in another corporation, it is also taxed as a dividend in kind. The basis of the warrant to an individual shareholder is its fair market value, 
see Q 
7503. 
 If a warrant is acquired through purchase, gift, or inheritance, there are no immediate income tax consequences. The tax basis of a warrant acquired in this manner is determined under general rules discussed in Q 
692.  
   
  1.   Treas. Reg. § 1.305-1(b).