The benefits of applying the binding contract rule are most evident in situations in which the parties to the reorganization
have agreed on a fixed amount of consideration and fixed the number of acquirer shares to be used in the total consideration.
In Revenue Procedure 81-70, the IRS acknowledges that, in the event the acquired target company is widely held, it would be "time consuming, costly, and burdensome" to collect tax basis data from the target shareholders involved in a "B" reorganization
Vencor and its subsidiaries filed voluntary petitions for reorganization
under Chapter 11 with the Court Sept.
See exhibit 1, page 80, for a review of selected quasi reorganization
D'Amato, and New York City Mayor David Dinkins, are supporting Secretary Aspin's decision to postpone and review implementation of the reorganization
Despite the fact that each of the merger participants is a foreign entity, the transaction nevertheless could be a statutory merger and thus a "good" type A reorganization
under the new regulations, because both Z and Y are qualified participants and the transaction is not divisive.
An S corp is a Qualified S Corp if it owns 100 percent of the Qualified Subsidiary immediately after the sale or reorganization
Those decisions, however, represent a shaky foundation for an elusive, yet pervasive, doctrine that permeates the Internal Revenue Code's reorganization
The IRS says the 50% test takes into consideration redemptions and other dispositions before the reorganization
Under terms of the company's bankruptcy plan of reorganization
, USG agreed to make three payments totaling $3.
In achieving reorganization
status, a transaction must fit one of the reorganization
67-125,(3) the Internal Revenue Service held that legal fees for advice on the tax significance of a potential reorganization
must be capitalized.