First of all, I have no idea of your level of experience, so please excuse any comments that may be too elementary in your situation.
1. My first comment to the client & attorney would be "Why".
2. Secondly, no matter what is done & how it's done, the potential for isolating the current and any future NOLs in the wrong place, is enough of a reason to be very careful of any reshuffling.
3. If there are 750K of NOLs and more to come that have been incurred, but yet quantified, you need to engage experts in this field before any action is taken as the $ are too big to screw up whatever is done.
4. These are complex areas of the tax code & not to be messed around with by amateurs (like me for example who has only be a CPA for 45+ year & is now retired - I spent 7 years with Coopers & Lybrand leaving as an Audit Manager, so if nothing else I learned to realize when I was in over my head). I would tell my client that we need to engage a consultant from one of the "Big 4" like PWC who has individuals who do nothing but this. Here's a link to an article which touches on some of this & even invites you to call some of the PWC individuals which I would recommend that you do as it will cost nothing to do so & whatever they say will be useful.
PWC has other similar articles which you can access: Google "Corporate Spin-offs"
That's a start, look for the PWC names at the end of that article as well as within the document, they tell you which one to call about the specific areas mentioned.
Hope this helps.
PS You mentioned RI; I know some of their best people are in Boston.