For example, shareholders of the target are permitted to receive boot (property other than stock of the acquiring corporation) in a type A reorganization
. A target shareholder who receives boot in a type A reorganization
recognizes gain to the extent of the lesser of the boot or the gain realized upon the exchange of the stock.
The fifth, and most recent, reorganization
took place under Cory Aquino in 1986, for which she used her revolutionary powers.
Section 361(a) states that no gain or loss to a corporation will be recognized if that corporation is a party to a reorganization
and exchanges property solely for stock of another corporation involved in the reorganization
Corporate-wide (macro-level) reorganization
efforts often include multiple micro-level reorganizations
within the umbrella of corporate-wide change efforts.
2) Divisive reorganizations
that are otherwise known as spin-offs, split-offs and split-ups.
Sections 221(2), 167, 167.1, and 156 in the GST provisions of the Excise Tax Act afford taxpayers relief from the obligation to collect and remit GST in connection with certain reorganization
transactions, but require taxpayers to satisfy a range of highly technical requirements.
The proposed regulations also address a wide range of technical issues on cross-border mergers under IRC section 368(a)(1)(A), including basis and holding periods, triangular reorganizations
, the application of sections 367 and 1248, and asset transfers.
Effect of the Tax-free Reorganization
Upon the Selling Shareholder.
Employees affected by the reorganization
initiatives retrained for other jobs, accepted other employment, or qualified for retirement.
Read how Aetna Life & Casualty's CFO helped lead the firm's reorganization
Meanwhile, of course, compromise is essential in any reorganization
have both established a single point of contact for company "clients" through an account executive team concept.