Transcription of Part I ISSUE
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Part I ISSUE
Part ISection 368. Definitions Relating to Corporate Reorganizations26 CFR : Purpose and Scope of Exception for Reorganization Rul. 2001-24 ISSUEW hether a controlling corporation s transfer of the acquiring corporation s stockto another subsidiary controlled by the controlling corporation as part of the plan ofreorganization, following the merger of the acquired corporation with and into theacquiring corporation, will cause the transaction to fail to qualify as a reorganizationunder 368(a)(1)(A) and 368(a)(2)(D) of the Internal Revenue to a plan of reorganization, corporation X merges with and intocorporation S, a newly organized wholly owned subsidiary of P, a corporation unrelatedto X, in a transaction intended to qualify as a reorganization under 368(a)(1)(A) and368(a)(2)(D).
Section 368(a)(1)(A) provides that the term reorganization includes a statutory merger or consolidation. Pursuant to § 368(a)(2)(D), the acquisition by one corporation,
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