Indicate the type of tax-free reorganization for each of the following statemen a. A transfer...

Indicate the type of tax-free reorganization for each of the following statemen

a. A transfer by a corporation of all or a part of its assets to another corporation in a bankruptcy or receivership proceeding.

b. A statutory merger or consolidation.

c. The acquisition by a corporation of substantially all of the property of another corporation in exchange for voting stock (voting-stock-for-asset exchange).

d. A mere change in identity, form, or place of organization.

e. The acquisition by a corporation of another using solely stock of each corporation (voting-stock-for-stock exchange).

f. The transfer of all or part of a corporation’s assets to another corporation when the original corporation’s shareholders are in control of the new corporation immediately after the transfer (acquisitive or divisive exchange: spin-off, split-off, or split-up).

g. A recapitalization.

Solutions

Expert Solution

Types of Reorganizations: Totally 7 under IRC Section 368

1.Aquisitive (Type A,B,C,D)

2. Divisive (Sub-category of Type D under certain rules)

3. Restructuring (Type E,F)

4. Bankruptcy (Type G)

Coming to the question

a. Type G reorganization which clearly is indicated by the name.

b. Type A reorganization and here the target's balance sheet is completely acquired by the acquiring company.

c. Type C reorganization and in this after necessary steps happen the target company liquidates.

d. Type F reorganization and here just a petty formality changes happens.

e. Type B reorganization and in this phenomenon the target company gives away ownership to the acquiring company to the extent of 75-85%.

f. Type D reorganization and here the target company acquires the control and ownership to 80% of the shareholdings.

e. Type E reorganization and this occurs due to the issue of new stock for the existing ones.

ekkarill92 answered 1 year ago

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