“C” Reorganization
“C” Reorganization
The target corporation must liquidate as part of the plan of reorganization unless the IRS waives this requirement.’ As a result, the shareholders of the target corporation become shareholders in the acquiring corporation. In determining the tax consequences to the liquidating target, the reorganization provisions govern-not the liquidation rules of §§ 336 and 337.
Explanation:
* Target exchanges substantially all its assets for voting stock of Acquiring.
* Target may receive a limited amount of boot in addition to the voting stock.
* Acquiring owns the assets of both Acquiring and Target.
* Target liquidates after the transfer, distributing Acquiring Company’s stock and any retained assets.
* Target’s former shareholders become shareholders in Acquiring.
We hope you found this article about “”C” Reorganization” helpful. If you have questions or need expert tax or family office advice that’s refreshingly objective (we never sell investments), please contact us or visit our Family office page or our website at www.GROCO.com. Unfortunately, we no longer give advice to other tax professionals gratis.
To receive our free newsletter, contact us here.
Subscribe to our YouTube Channel for more updates.
Alan Olsen, is the Host of the American Dreams Show and the Managing Partner of GROCO.com. GROCO is a premier family office and tax advisory firm located in the San Francisco Bay area serving clients all over the world.
Alan L. Olsen, CPA, Wikipedia Bio
GROCO.com is a proud sponsor of The American Dreams Show.
The American Dreams show was the brainchild of Alan Olsen, CPA, MBA. It was originally created to fill a specific need; often inexperienced entrepreneurs lacked basic information about raising capital and how to successfully start a business.
Alan sincerely wanted to respond to the many requests from aspiring entrepreneurs asking for the information and introductions they needed. But he had to find a way to help in which his venture capital clients and friends would not mind.
The American Dreams show became the solution, first as a radio show and now with YouTube videos as well. Always respectful of interview guest’s time, he’s able to give access to individuals information and inspiration previously inaccessible to the first-time entrepreneurs who need it most.
They can listen to venture capitalists and successful business people explain first-hand, how they got to where they are, how to start a company, how to overcome challenges, how they see the future evolving, opportunities, work-life balance and so much more..
American Dreams discusses many topics from some of the world’s most successful individuals about their secrets to life’s success. Topics from guest have included:
Creating purpose in life / Building a foundation for their life / Solving problems / Finding fulfillment through philanthropy and service / Becoming self-reliant / Enhancing effective leadership / Balancing family and work…
MyPaths.com (Also sponsored by GROCO) provides free access to content and world-class entrepreneurs, influencers and thought leaders’ personal success stories. To help you find your path in life to true, sustainable success & happiness. It’s mission statement:
In an increasingly complex and difficult world, we hope to help you find your personal path in life and build a strong foundation by learning how others found success and happiness. True and sustainable success and happiness are different for each one of us but possible, often despite significant challenges.
Our mission at MyPaths.com is to provide resources and firsthand accounts of how others found their paths in life, so you can do the same.
Mergers & Acquisitions
Mergers & Acquisitions Grow your firm by merging with GROCO. As with most firms, the best way to get to know GROCO is to read our web site. On the right hand side you can click on the word “Brochure” to get a fairly concise overview of the firm. The more one browses, hopefully, the…
Another Poor Showing for the U.S. Tax System
Another poor showing for the U.S. tax system? It seems that every day a new list of rankings is released about the locations where we live. Which state is best for owning a home, or which city has the highest vitality rate, are some of the topics discussed in previous lists, for example. Everyone has…
Overseas Account Penalties Increase As More Banks Sign On
Overseas Account Penalties Increase As More Banks Sign On It seems that every month we share an article describing the ever-increasing reach of the IRS throughout the world as they attempt to put a stop to any and all taxpayers who would try to avoid paying their fair amount of taxes. This month is no…
Tax on Foreign Income of US Citizens or Residents
Tax on Foreign Income of US Citizens or Residents Foreign Earned Income Exclusion Individual US citizens and residents are taxed on their worldwide income. However, IRC Sec. 911 provides that qualified taxpayer can elect to exclude foreign earned income up to $87,600 from taxable income. (Read IRS Pub 54 for more details.) The qualifications are:…