A financial holding company may not acquire
or control merchant banking investments under this subpart unless the financial holding company qualifies under at least one of the following paragraphs:
Section 355(e) will only apply to a distribution that is part of a "plan" pursuant to which a person or persons acquire
a 50-percent or greater interest in the distributing or any controlled corporation.
The appellate court reasoned that the taxpayer's sale of shares for cash was entered into before and without prior knowledge of Churchill's intention to acquire
all of Bruce Company's stock.
Specifically, the QSP-SFVS exception provides that the acquiring corporation's use of consideration other than solely the acquiring corporation's voting stock to acquire
the target in a QSP "will not prevent the subsequent transfer of [the target's] assets from satisfying the solely-for-voting-stock requirement for purposes of determining if the transfer of [the target's] assets qualifies as a [C reorganization]" (Regs.
Acquisition of T's stock: If P acquires
T's stock, Sec.
D agreed to acquire
Corporation T's assets in a statutory merger.
In 1982, La Crosse was formed to acquire
the assets of Rubber Mills.
368(a)(1)(C), an acquiring corporation must acquire
substantially all of the properties of a target in exchange solely for its voting stock (or solely for voting stock of its parent).