and the Neova dermatological products business from PhotoMedex, Inc., in a transaction structured in two reverse triangular mergers
, with a non-dilutive provision, DS said.
351 exchanges, certain reverse triangular mergers
, and certain triangular reorganizations involving foreign corporations.
Under current law, a merger transaction effected pursuant to foreign law does not qualify as an "A" reorganization, because, as noted above, by definition, such a transaction cannot be a "statutory merger or consolidation." Likewise, forward-triangular mergers (35) and reverse triangular mergers
(36) undertaken pursuant to foreign law are not available because both types of reorganizations require that the transaction would otherwise qualify as an "A" reorganization.
81-70's use was expanded to apply to certain reverse triangular mergers under Treas.
Taxpayers previously involved in tax-free stock-for-stock exchanges qualifying as either a "B" reorganization or a reverse triangular merger could be significantly affected by the IRS's final word on basis study computation.
368(a)(1)(C)), and forward or reverse triangular mergers
For this purpose reverse triangular mergers
98-10 is consistent with the regulations governing reverse triangular mergers
However, forward and reverse triangular mergers
are less flexible than straight mergers.
368(a)(2)(C)), or to permit forward and reverse triangular mergers