“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.
Will Your Tax Return Draw the IRS’s Attention?
No one wants to experience a tax audit. The good news is that most people never will have to go through that experience. The IRS simply doesn’t have the time and resources to audit every tax return. In fact, the IRS only audits about 1 percent of all returns. That means most people don’t have…
Can a Roth Really Help You Lower Your Taxes?
Patience is a virtue, but will it save you money on taxes? That depends on the situation, but if you’re talking about a Roth IRA, then the answer is typically yes. Traditional IRAs will usually give you an immediate tax savings, while a Roth IRA won’t. However, for those who have patience, a Roth can…
What Are the Wealthy Really Worried About?
At GROCO we work very closely with some of the most highly successful people in the world and because of that we know what makes these types of individuals tick. We understand how they think and how they operate and we offer top notch business consulting to help them be successful. We also know what…
Does it Really Pay to Win the Lottery?
Everyone dreams of winning the lottery. The thought of taking home hundreds of millions of dollars is enough to get even the laziest people off the couch and into their local quick-e-mart to purchase some tickets. The country has been abuzz during the last several days over the huge Powerball jackpot that ultimately reached $1.6…