Search results with tag "Free type d business reorganizations"

Structuring Tax -Free Type D Business Reorganizations

Mar 18, 2014 · Continuity of business enterprise does apply, but usually is met by virtue of T transferring substantially all of its assets to A. A non-tax corporate business purpose is also required. Reg. § 1.368-2(l) permits “all cash” D reorganizations to satisfy § 368(a)(1)(D) so long as A and T’s shareholders own the two

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