: There are many reasons for pursuing a tax-free acquisitive reorganization
, such as (1) increasing revenue; (2) improving financial performance (particularly if not possible through organic growth); (3) achieving economies of scale; (4) improving technological capabilities; or (5) expanding into new areas, products, or customer base.
The process was declared completed in 1973, but the commission set up for the purpose was allowed to pursue reorganization
Under Letter Ruling 9252001, like-kind treatment survived both a type A reorganization
and a divisive type D reorganization
So, the reorganization
plan must provide the measures and the ways through which the activity of the company will be redressed and how the debts can be paid by the company in a period of three years.
Volumes of material have been generated on the macro-level, corporate-wide, reorganization
US Airways Chairman and CEO Doug Parker said yesterday that the assumptions underlying Delta Air Lines' standalone reorganization
plan are "out of whack" and that warnings of a US/DL merger being derailed by antitrust issues are "misleading" and "superficial.".
In acquisition reorganization
, the acquiring corporation ultimately ends up in control of the target corporation's assets or stock.
TEI urges the Standing Committee to recommend that the GST relief rules be simplified and expanded in order to eliminate the imposition of GST on transfers of property among affiliates in connection with reorganizations
of corporate groups.
Because many foreign jurisdictions now have merger statutes that operate like those of the states, whereby all assets and liabilities move by operation of law, this change in the definition of an A reorganization
allows such foreign transactions to qualify, for purposes of IRC section 368(a)(1)(A), as a statutory merger or consolidation if they satisfy the functional criteria applicable to transactions under domestic statutes.
If the selling shareholders receive stock in the buying corporation in consideration of their business' sale, then the selling shareholders may be able to avoid recognizing gain under the tax-free reorganization
rules of Sec.
Conseco Inc.'s plan for reorganization
has been approved by the court, paving the way for the company to come out of bankruptcy as an insurance-only operation.
subsidiaries (except The G&C Foundry Co., Sandusky, Ohio) have filed a voluntary petition for reorganization
. The firm's Canadian and U.K.