National Tax 432 Chapter 17 Solutions

National Tax 432 Chapter 17 Solutions -...

Info iconThis preview shows pages 1–2. Sign up to view the full content.

View Full Document Right Arrow Icon
Types of Reorganization 1. There are seven types of reorganization as defi ned in Code Sec. 368(a)(1): (1) Type A: Statutory merger or consolidation (2) Type B: Acquisition of stock in exchange for voting stock (3) Type C: The acquisition of substantially all assets in exchange for voting stock (4) Type D: Acquisition of assets for stock; divisive transfer of assets in exchange for stock, followed by a distribution of stock (5) Type E: Recapitalization of one corporation (6) Type F: Mere change in form, location, or identity of one corporation (7) Type G: Reorganization of insolvent or bankrupt corporation Acquisitive Reorganizations 2. The acquisitive types of statutory reorganization include: Type A—statutory merger or consolidation; Type B— acquisition of stock; Type C—acquisition of assets; and an acquisitive Type D. Continuity of Business Enterprise/Proprietary Interest 3. Continuity of business enterprise refers to whether the acquired corporation’s historic business assets are retained after the acquisition. Generally, a minimum of one-third of the assets must be retained and used in a business. Continuity of proprietary interest refers to whether the acquired corporation’s shareholders have an equity (stock) interest in the acquiring corporation after the acquisition. Generally, a minimum of 50 percent of consideration given to the acquired corporation’s shareholders must be stock of the acquiring corporation to satisfy this requirement. Continuity of Proprietary Interest
Background image of page 1

Info iconThis preview has intentionally blurred sections. Sign up to view the full version.

View Full DocumentRight Arrow Icon
Image of page 2
This is the end of the preview. Sign up to access the rest of the document.

Page1 / 3

National Tax 432 Chapter 17 Solutions -...

This preview shows document pages 1 - 2. Sign up to view the full document.

View Full Document Right Arrow Icon
Ask a homework question - tutors are online