“E” Reorganization
“E” Reorganization
The “E” reorganization is defined as a re-capitalization – the exchanges of stock and securities for new stock and/or securities by the corporation’s shareholders. It involves only one corporation and the re-configuration of its capital structure.
Stock for stock
Differences in the voting rights, dividend rates, and preference on liquidation are ignored.
Bonds for Bonds
If the principal amount of the bonds received exceeds the principal amount of the bonds surrendered, gain must be recognized.
Stock for Bonds
Exchanges of stock for bonds by shareholders generally do not qualify as “E” reorganization since the shareholders upgrade their investment position. The income is recognized and treated as dividends or capital gains.
“F” Reorganization
“F” reorganization is defined as “a mere change in identity, form, or place of organization of one corporation, however effected.” The “F” reorganization rules normally apply when the corporation changes its name, state of operation, or makes other changes in its corporate charter. In such case, there is a deemed transfer from the old corporation to the new corporation.
“G” Reorganization
“G” reorganization applies to reorganization as part of bankruptcy. It permits the transfer of some or all of the assets of a failing corporation to a new controlled corporation provided the stock and securities of the controlled corporation are distributed to the old corporation’s shareholders under the rules for distributions in a “D” reorganization.
Return to Details of Patterns of Reorganization
To receive our free newsletter, contact us here.
Subscribe 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.
Believe it or Not, Clinton, Trump Do Agree on Something
Believe it or Not, Clinton, Trump Do Agree on Something Are you ready for the election to be over? While all presidential elections seem to bring out some of the worst in people, this one appears to have reached new levels of animosity and contention, which is constantly on display in the media. It’s no…
Best and Worst States for Taxes for Startup Companies
Best and Worst States for Taxes for Startup Companies Startup companies face many forms of opposition as they set out to change the world, or at least carve out their own niche – even though they are typically working to provide solutions. That doesn’t mean that people or other businesses oppose them, necessarily, but rather…
Inboard- Disrupting Urban Transportation
Inboard- Disrupting Urban Transportation I recently met with Ryan Evans, CEO and Co-Founder of Inboard Technology. What he and his business partner have been able to accomplish with Inboard, in a relatively short period of time is amazing! From creating the first electric skateboard with motorized wheels to raising over $400,000 on Kickstarter, Inboard has…
Taxes for Dummies
This is a great video explaining the US Government’s progressive tax system for those who don’t understand it! Is it fair that 16% of American taxpayers payed nearly 80% of all federal tax in 2014? Just to have politicians say that the wealthy haven’t payed their “fair share” yet.