RE:Tax Implications .I only speak as it pertains to U.S. taxpayers. For us, the distribution will be a dividend to the extent that there are positive Earnings and Profits. Considering that SVBL has no positive E &P, the entrie distribution for U.S. taxpayers will be considered a return of capital. In the event that the value assigned to Arras shares on the day of your distribution exceeds the basis you have in SVBL shares, the excess would be a capital gain. Otherwise, the basis assigned to your Arras shares should be subtracted from your basis in your SVBL shares.
At a minimum, your total adjusted basis between the Arras and SVBL shares should be at least as much as your original basis in your SVBL shares. Some of us may get lucky and some "free basis" may sneak into the mix, but one shouldn't necessarily expect that.